Justia Civil Rights Opinion Summaries

Raymond Tackett, an inmate with the Indiana Department of Corrections (IDOC), suffered from Hepatitis C (HCV) and did not receive direct-acting antivirals (DAAs), a treatment that cures HCV. He died on November 29, 2019, from complications related to HCV. His daughter, Skyler Tackett, as the personal representative of his estate, filed an Eighth Amendment deliberate indifference claim and a state law medical malpractice claim against the medical professionals who treated him, Wexford Health Services, and Dr. Kristen Dauss, the Chief Medical Officer of the IDOC. She later dismissed all claims except the deliberate indifference claim against Dr. Dauss.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Dr. Dauss, finding that she took reasonable steps to expand access to DAAs and was not responsible for the treatment decisions that led to Mr. Tackett’s death. Ms. Tackett appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The court found that Ms. Tackett presented insufficient evidence for a reasonable jury to find Dr. Dauss liable in her individual capacity. The court noted that Mr. Tackett was in a treatment priority group and that Nurse Myers had requested DAAs for him, but there was no evidence that Dr. Dauss’s actions or the IDOC policy prevented him from receiving the treatment. The court concluded that while Mr. Tackett’s death was tragic, there was no evidence that Dr. Dauss’s actions amounted to deliberate indifference under the Eighth Amendment. View "Tackett v Dauss" on Justia Law

Jeremy James Allen, while incarcerated at the Minnesota Correctional Facility in Faribault, filed a complaint against several officials alleging deliberate indifference and medical malpractice related to a hand injury from December 2017. He did not file any grievances with prison officials regarding his injury or medical treatment during his incarceration. Allen's complaint was initially filed in state court and later removed to federal court. After his release from custody, Allen amended his complaint, substituting Charles Brooks and Cheryl Piepho for previously unidentified defendants.The United States District Court for the District of Minnesota granted Allen's unopposed motion to amend his complaint after his release. The defendants moved to dismiss the complaint for lack of subject matter jurisdiction and failure to state a claim, but did not initially raise the issue of exhaustion of administrative remedies. The district court denied the motion to dismiss on qualified immunity grounds, finding that Allen plausibly alleged a violation of his Eighth Amendment right to adequate medical care.Brooks and Piepho later raised the failure to exhaust defense in a summary judgment motion, arguing that Allen's original complaint, filed while he was incarcerated, was subject to the Prison Litigation Reform Act (PLRA) exhaustion requirement. The district court denied their motion, ruling that the amended complaint, filed after Allen's release, was not subject to the PLRA's exhaustion requirement and did not relate back to the original complaint under Federal Rule of Civil Procedure 15(c).The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court held that Allen's amended complaint, filed after his release, was the operative complaint and not subject to the PLRA's exhaustion requirement. Additionally, the court found that the amended complaint did not relate back to the original complaint because naming John and Jane Doe defendants did not qualify as a "mistake" under Rule 15(c). View "Allen v. Brooks" on Justia Law

Sandra Jones, representing the estate of her deceased son Antonio Jones, filed a lawsuit under 42 U.S.C. § 1983 and Arkansas state law against Faulkner County, Arkansas, and jail officials Garry Stewart, Karen Grant, and Leanne Dixon. She claimed that the officials exhibited deliberate indifference to Antonio’s serious medical needs, violating his Fourteenth Amendment rights, and that Stewart committed medical malpractice. Jones also alleged that Faulkner County’s policies contributed to Antonio’s death.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. The court found that the jail officials were not deliberately indifferent to Antonio’s medical needs and that Jones could not establish a medical malpractice claim against Stewart due to the absence of a doctor-patient relationship. The court also dismissed the municipal liability claim against Faulkner County, concluding that no jail policy caused Antonio’s death.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the actions taken by Grant and Dixon did not constitute deliberate indifference. Grant responded to Antonio’s symptoms by placing him on a medical watch and took appropriate actions based on the information available to her at the time. Dixon, who was not a medical professional, followed her superior’s instructions and did not disregard any substantial risk of harm. The court also affirmed the dismissal of the municipal liability claim, as there was no constitutional violation by the county employees. Lastly, the court found no abuse of discretion in the district court’s exercise of supplemental jurisdiction over the state law claim against Stewart. View "Jones v. Faulkner County, Arkansas" on Justia Law

Clover Boykin filed a lawsuit against Greenwood Leflore Hospital (GLH) under 42 U.S.C. § 1983, alleging that GLH intentionally withheld her medical records, preventing her from filing a medical malpractice suit. Boykin claimed that GLH's actions violated her constitutional right of access to the courts. GLH responded with a motion to dismiss, arguing that Boykin's claims failed as a matter of law, the employee was immune from suit, GLH was never served, and the suit was time-barred.The Leflore County Circuit Court denied GLH's motion to dismiss and granted Boykin additional time to serve GLH. GLH then sought an interlocutory appeal, which the Supreme Court of Mississippi granted. Boykin did not file a brief in response to the appeal.The Supreme Court of Mississippi accepted Boykin's failure to file a brief as a confession of error and found that Boykin's claims failed as a matter of law. The court held that HIPAA does not provide a private right of action and that Boykin could not use § 1983 to enforce a federal statute that does not give her an individual right. The court reversed the trial judge's denial of the motion to dismiss and rendered judgment in favor of GLH. View "Greenwood Leflore Hospital v. Boykin" on Justia Law

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