Bobby Grady v. Fane Greenfield, 670 F. App'x 818

Plaintiff Bobby Ray Grady, pro se, sued under 42 U.S.C. § 1983 alleging deliberate indifference to serious mental illness and improper isolation conditions by detention-center staff.
Defendants moved for summary judgment; the district court granted judgment for defendants.
On appeal Grady argued the district court overlooked his claim against supervisory defendant Greenfield for deliberate indifference and state-law violations.
Greenfield was a supervisory official, not medical staff; Grady did not allege Greenfield ignored medical staff opinions.
Record shows Grady received treatment at the Detention Center and did not bring his specific concerns to Greenfield or through the grievances in the record.
The court reviewed whether, under summary judgment standards, any genuine dispute of material fact precluded judgment for defendants on the deliberate-indifference claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Greenfield was deliberately indifferent to Grady’s serious mental-health needs	Greenfield’s actions and placement in isolation exacerbated his mental illness and violated state law	Greenfield was a supervisor (not medical personnel), did not ignore medical opinions, and relied on medical staff; state-law violations do not create § 1983 liability	No genuine dispute: Grady failed to show Greenfield was deliberately indifferent; summary judgment affirmed
Whether disagreement with treatment establishes deliberate indifference	Disagreement over adequacy of care shows constitutional violation	Disagreement with medical care, without more, is insufficient to show deliberate indifference	Held: Mere disagreement or negligence does not meet the high deliberate-indifference standard
Whether violation of state law supports § 1983 claim	State-law violations contribute to constitutional claim	Violation of state law alone is insufficient to establish § 1983 liability	Held: State-law violations do not satisfy § 1983 requirements
Whether failure to exhaust or raise grievances against Greenfield defeats the claim	Grady contends his grievances/records support his claim	Record lacks grievances or notice to Greenfield about the specific claim	Held: Grady did not show he informed Greenfield or exhausted grievances relevant to this claim; weighs against finding deliberate indifference

Grayson v. Peed, 195 F.3d 692 (4th Cir. 1999) (deliberate indifference requires an apparent and serious medical need and a culpable mental state)
Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (mere negligence or disagreement in medical treatment does not constitute Eighth Amendment deliberate indifference)
Wright v. Collins, 766 F.2d 841 (4th Cir. 1985) (disagreements between inmate and physician do not show deliberate indifference absent exceptional circumstances)
Davis v. Scherer, 468 U.S. 183 (U.S. 1984) (state-law violations do not automatically give rise to § 1983 liability)
Hamby v. Hammond, 821 F.3d 1085 (9th Cir. 2016) (prison officials may rely on medical opinions when addressing inmates’ medical needs)