Justia Civil Rights Opinion Summaries

Clarence Lewis, an inmate at Hill Correctional Center, sued various medical staff members, alleging they were deliberately indifferent to his health issues, violating the Eighth Amendment. Lewis claimed misdiagnosis and mistreatment of diabetes, COPD, irritable bowel syndrome, and Hepatitis C. He also contended that his grievance about a delay in diabetes medication was not properly addressed.The United States District Court for the Central District of Illinois denied Lewis's motions for recruited counsel, stating he could represent himself and obtain relevant documents. The court granted summary judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, concluding no reasonable juror could find deliberate indifference. The court also granted summary judgment for Dr. Paul, citing claim splitting due to a similar prior lawsuit.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, finding no reasonable likelihood that recruited counsel would have changed the outcome. The court noted that Lewis's disagreement with his diagnoses and treatments did not constitute deliberate indifference. As for Administrator Lindor, her limited role and the lack of harm from the medication delay further supported the judgment.However, the court vacated the judgment in favor of Dr. Paul, agreeing with Lewis that the district court's application of claim splitting was erroneous. Dr. Paul had raised this defense too late, effectively acquiescing to the claim. The case was remanded for further proceedings regarding Dr. Paul, with the district court advised to reconsider Lewis's request for recruited counsel if the claim proceeds to trial. View "Lewis v Sood" on Justia Law

While incarcerated at Woodborne Correctional Facility, Antonio Mallet sought medical care for urinary obstruction and painful urination, symptoms indicative of prostate cancer. Despite a cystoscopy revealing concerning results, prison doctors did not conduct further tests for prostate cancer, instead prescribing medication for a benign enlarged prostate. Mallet was released on parole in January 2019 and was diagnosed with late-stage prostate cancer in May 2021. He filed a lawsuit on February 25, 2022, against the State of New York, the New York State Department of Corrections and Community Supervision (DOCCS), its acting commissioner, and three medical providers, alleging deliberate indifference to his medical needs and other constitutional violations, as well as state law claims for malpractice and negligence.The United States District Court for the Southern District of New York dismissed Mallet’s constitutional claims as untimely, reasoning that the claims accrued by the time he was released from custody in January 2019, thus falling outside the three-year statute of limitations for Section 1983 claims in New York. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Second Circuit found it plausible that Mallet’s deliberate indifference claim had not accrued by February 25, 2019, making his complaint potentially timely. The court reversed the district court’s dismissal of the deliberate indifference claims against Dr. Makram and Dr. Stellato, finding them plausible, but affirmed the dismissal of the claim against Professor Ritaccio and the constitutional claims against New York State, DOCCS, and Annucci due to sovereign immunity. The court vacated the dismissal of the remaining constitutional claims and state law claims, remanding the case for further proceedings. View "Mallet v. New York State Department of Corrections and Community Supervision" on Justia Law

The case involves the Estate of Charles Anthony Hurtado, which brought an action against Dr. Jerry A. Smith, alleging that Dr. Smith acted with deliberate indifference to Mr. Hurtado’s serious medical needs. Mr. Hurtado, an inmate, was treated for a perineal abscess at a medical center where Dr. Smith performed a diagnostic needle aspiration but did not find an abscess cavity. Dr. Smith prescribed oral antibiotics and pain medication, and Mr. Hurtado was discharged. Later that evening, Mr. Hurtado returned to the emergency room with intense pain, was diagnosed with sepsis, and underwent surgery. He was later transferred to another hospital where he died from complications related to the abscess and other health issues.The United States District Court for the District of Colorado granted summary judgment in favor of Dr. Smith. The court found no genuine dispute of material fact regarding whether Dr. Smith knew of and disregarded a significant risk to Mr. Hurtado’s health. The court concluded that even if Dr. Smith’s diagnosis and treatment were incorrect, they did not rise to the level of deliberate indifference but were, at most, medical negligence.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court held that there was no evidence from which a jury could infer that Dr. Smith consciously disregarded a substantial risk to Mr. Hurtado’s health. The court noted that Dr. Smith’s treatment was not patently unreasonable and that the expert testimony provided by the plaintiff did not establish deliberate indifference but rather suggested medical negligence. The court emphasized that deliberate indifference requires more than a misdiagnosis or negligence; it requires a showing that the medical professional knew of and disregarded an excessive risk to the inmate’s health. View "Estate of Hurtado v. Smith" on Justia Law

Wade Jones was incarcerated at the Kent County Correctional Facility for five days in April 2018. During his incarceration, he experienced severe alcohol withdrawal symptoms. Despite being placed on an alcohol-withdrawal protocol, Jones did not receive timely or adequate medical care. On April 27, 2018, Jones went into cardiac arrest and was later transferred to a hospital, where he died a week later. His estate sued Kent County and several nurses, alleging deliberate indifference to his medical needs.The United States District Court for the Western District of Michigan held a trial where a jury found that nurses Melissa Furnace, Chad Goetterman, and James Mollo were deliberately indifferent to Jones’s medical condition, which was a proximate cause of his death. The jury awarded Jones’s estate $6.4 million in compensatory damages. The defendants moved for judgment as a matter of law or a new trial, arguing that the jury’s verdict was inconsistent, that no reasonable jury could find proximate cause, that the estate’s counsel engaged in misconduct, and that a juror’s failure to disclose his criminal history warranted a new trial. The district court denied these motions.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the defendants had forfeited their inconsistent-verdict argument by not objecting before the jury was discharged. It also found sufficient evidence to support the jury’s finding of proximate cause, noting that the jury could reasonably conclude that the nurses’ failure to provide timely medical care significantly decreased Jones’s likelihood of survival. The court further held that the estate’s counsel’s emotional display during trial did not constitute contumacious conduct warranting a new trial. Lastly, the court found no basis for a new trial due to juror misconduct, as the juror was never directly asked about his own criminal history during voir dire. View "Jones v. Kent County" on Justia Law

The plaintiff, Richard Rodgers, a prisoner with a history of scoliosis and back pain, had steel rods implanted in his back prior to his incarceration. During his time in prison, the rods broke, but this went undetected for over a year due to two radiologists misreading his x-rays. The prison's primary care physician, Dr. William Rankin, discovered the broken rods and arranged for corrective surgery. Rodgers sued the radiologists and Dr. Rankin, alleging violation of his Eighth Amendment rights.The district court dismissed Rodgers' claims against the radiologists, finding that he did not state a viable constitutional claim against them. The court allowed Rodgers to proceed against Dr. Rankin but eventually granted summary judgment in his favor. The court found that Rodgers had not provided evidence that would allow a reasonable jury to find that Dr. Rankin had violated the Eighth Amendment by acting with deliberate indifference toward Rodgers' serious medical condition.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court agreed that Rodgers' allegations against the radiologists amounted to no more than negligence, which is insufficient to state a viable Eighth Amendment claim. Regarding Dr. Rankin, the court found that the evidence would not support a reasonable finding that he acted with deliberate indifference to Rodgers' serious medical condition. The court noted that Dr. Rankin was the one who discovered the radiologists' errors and arranged for Rodgers' corrective surgery. View "Rodgers v. Rankin" on Justia Law

Edward Zaragoza, an inmate suffering from hypothyroidism, filed a lawsuit against three prison physicians and their employer. Zaragoza claimed that the doctors' treatment decisions, specifically their refusal to provide alternative medication despite the severe side effects he experienced from the prescribed medication, amounted to medical malpractice and deliberate indifference to his serious medical needs. The Indiana Supreme Court found that Zaragoza's expert's affidavit, which challenged the doctors' treatment decisions, was both admissible and substantively sufficient to create an issue of fact in the malpractice case. The court also found that there were disputes over whether the doctors knowingly failed to offer Zaragoza a potentially safer alternative medication. Thus, the court ruled that summary judgment was not warranted and reversed the trial court's decision, allowing Zaragoza's claims to proceed to trial. The court emphasized that summary judgment is not a summary trial and that genuine issues of material fact remained to be determined by a factfinder after a trial. View "Zaragoza v. Wexford of Indiana, LLC" on Justia Law

Dean, incarcerated since 2012, developed kidney cancer. Seven months after he first presented symptoms, Dean had kidney-removal surgery. The cancer had already spread to his liver, Dean remains terminally ill. Dean sued his doctors and their employer, Wexford, a private corporation that contracts to provide healthcare to Illinois inmates, alleging deliberate indifference to his serious medical needs in violation of the Eighth Amendment. Dean cited delays in his diagnosis and treatment, caused by his doctors’ failure to arrange timely off-site care, and on a policy that requires Wexford’s corporate office to pre-approve off-site care.A jury awarded $1 million in compensatory damages and $10 million in punitive damages, which was reduced to $7 million. The Seventh Circuit reversed. Dean has endured great suffering, but he did not produce enough evidence to hold any of the defendants liable for violating the Eighth Amendment. Dean’s claim against Wexford hinged on two expert reports from another case that critique the medical care, and process for medical care, that Illinois provides, through Wexford, to its prisoners. Those reports are hearsay, but the district court allowed Dean to use them for a non-hearsay purpose: to prove that Wexford had prior notice of the negative assessments of its review policy. One report postdated all events relevant to Dean and could not have given Wexford prior notice. The other report alone was insufficient to hold Wexford liable under the exacting “Monell” requirements in this single-incident case. View "Dean v. Wexford Health Sources, Inc." on Justia Law

Inmate Robinson was offered new medication. Unaware of any prescription, he questioned the officer who gave it to him and followed up with the health services manager and others. Despite learning that there was no record of any new prescription for him, Robinson took the medication. Days later, Robinson passed out. A nurse advised him to keep taking the medication. Robinson then was sent to an outside hospital, where doctors surmised that he might be allergic to the medication. The prescription was meant for a different inmate. Robinson sued. The defendants moved for summary judgment; 20 days after his deadline for filing a brief in opposition, Robinson filed a brief to support his own request for summary judgment, supplemented by a proposed statement of facts. He did not respond to the defendants’ statement of facts. The district court granted the defendants summary judgment.The Seventh Circuit affirmed. The district court permissibly applied Eastern District of Wisconsin Local Rule 56(b)(4) to deem the defendants’ facts unopposed, regardless of Robinson’s later filings. Based on those facts, no reasonable jury could find deliberate indifference to a serious medical risk. Nor could a jury conclude that the health‐services manager violated his constitutional rights by failing to intervene. Robinson’s state‐law negligence claims were barred by Wisconsin’s notice‐of‐claim statute. The defendants were not entitled to summary judgment based only on Robinson's failure to timely respond. View "Robinson v. Waterman" on Justia Law

The Supreme Court held that claims pleaded under 42 U.S.C. 1983 that were asserted against a state mental health facility and its employees arising from the death of a patient are health care liability claims subject to the Texas Medical Liability Act (TMLA) and that section 1983 does not preempt the TMLA's expert report requirement.Plaintiff sued Rio Grande State Center (RGCS) and ten individual defendants after his son died in RGSC's care. As to RGSC, Plaintiff alleged negligence, and as to the individual defendants, Plaintiff asserted claims under 42 U.S.C. 1983. Defendants moved to dismiss the claims for failure to serve an expert report under Tex. Civ. Prac. & Rem. Code 74.351(b). The trial court denied the motion to dismiss, and Plaintiff nonsuited the negligence claim against RGSC. The court of appeals affirmed, holding that the expert report requirement of the TMLA was preempted by section 1983. The Supreme Court reversed, holding (1) Plaintiff's claims were health care liability claims subject to the TMLA; and (2) section 1983 does not preempt the TMLA's expert-report requirement. View "Rogers v. Bagley" on Justia Law

In 2015, inmate Peterson suffered from genital warts. Davida, a Stateville Correctional Center physician employed by Wexford, prescribed a topical medication (Podocon-25), which is caustic and should be applied sparingly, then removed thoroughly. PODOCON-25's packaging states that “PODOCON-25© IS TO BE APPLIED ONLY BY A PHYSICIAN” and warns of multiple potential “ADVERSE REACTIONS.” Davida did not apply the Podocon-25, nor did the nurses, who instructed Peterson to apply the treatment himself. He did so and suffered personal injuries.In 2016, Peterson filed a pro se complaint against Davida, the nurses, and Illinois Department of Corrections officials under 42 U.S.C. 1983. He alleged that the officer-defendants destroyed his shower pass permits, issued as part of his treatment, or failed to intervene to correct the situation. The court granted Peterson leave to proceed in forma pauperis and dismissed his claims except as to three correctional officers. After obtaining counsel, Peterson filed an amended complaint, adding Wexford. The parties stipulated to dismissal without prejudice on January 25, 2018. On January 21, 2019, Peterson filed the operative complaint, claiming deliberate indifference under section 1983 and negligence under Illinois law against Davida, the nurses, and Wexford. The district court dismissed, finding that the complaint failed to sufficiently allege that the defendants had the requisite state of mind for deliberate indifference and that Peterson’s negligence claims were untimely because his 2016 complaint did not contain those allegations; the relation-back doctrine governs only amendments to a complaint, not a new filing.The Seventh Circuit affirmed the dismissal of the section 1983 claims but reversed as to the negligence claims. The court did not consider 735 ILCS 5/13-217, under which plaintiffs have an “absolute right to refile their complaint within one year” of its voluntary dismissal. View "Peterson v. Wexford Health Sources, Inc." on Justia Law