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Charlie J. Williams v. Morris A. Young
695 F. App'x 503
| 11th Cir. | 2017
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Background

  • Williams, a pretrial detainee at Leon County Jail, had a diagnosed inguinal hernia and arrived at the jail on June 22, 2011.
  • Jail nurses and Corizon physicians examined him repeatedly; Dr. Flodin arranged a surgical consult and prescribed pain medication.
  • A general surgeon (Dr. Neal) evaluated Williams on July 19 and deemed surgery necessary but elective (not urgent); Williams was released on house arrest to obtain surgery, but the procedure was postponed for reasons not shown to be Defendants’ fault.
  • After returning to jail, Williams received ongoing nursing checks, pain medication, a hernia belt, and closer monitoring; Dr. Garcia admitted him to the infirmary, later classified him as a chronic patient, increased pain meds, and ordered another surgical consult.
  • On September 16–17, after worsening pain, Williams was sent to the hospital and underwent surgical repair.
  • Williams sued under 42 U.S.C. § 1983 (deliberate indifference) and Florida negligence; the district court granted summary judgment for Corizon and the Sheriff, and the Eleventh Circuit affirmed.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Deliberate indifference to a serious medical need Williams: delay in performing hernia surgery and insufficient pain medication caused unnecessary pain Defendants: provided regular evaluations, arranged surgical consults, treated symptoms, and hernia was non-urgent per multiple doctors Court: No deliberate indifference; disagreement over timing/treatment is medical judgment, not constitutional violation
State-law negligence by Sheriff Williams: jail staff failed to ensure adequate medical care Sheriff: care was provided; any claim is medical negligence requiring pre-suit compliance Court: Claim is medical negligence; Williams failed to satisfy Fla. Stat. § 766.106 pre-suit requirements, so summary judgment proper

Key Cases Cited

  • Harris v. Thigpen, 941 F.2d 1495 (11th Cir. 1991) (constitutional violation requires care so grossly inadequate as to shock the conscience)
  • Maniccia v. Brown, 171 F.3d 1364 (11th Cir. 1999) (summary judgment standard and view of evidence for nonmoving party)
  • Taylor v. Adams, 221 F.3d 1254 (11th Cir. 2000) (deliberate indifference requires conduct beyond negligence or malpractice)
  • Adams v. Poag, 61 F.3d 1537 (11th Cir. 1995) (differences in medical judgment do not establish constitutional liability)
  • Rooney v. Watson, 101 F.3d 1378 (11th Cir. 1996) (policy/custom inquiry follows proof of a constitutional deprivation)
  • Mann v. Taser Int’l, Inc., 588 F.3d 1291 (11th Cir. 2009) (pretrial detainee claims analyzed under Fourteenth Amendment but evaluated like Eighth Amendment inadequate-care claims)
  • Goebert v. Lee Cty., 510 F.3d 1312 (11th Cir. 2007) (same standard for pretrial detainee medical claims as for Eighth Amendment)
  • Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014) (abandonment of claims not pursued on appeal)
Read the full case

Case Details

Case Name: Charlie J. Williams v. Morris A. Young
Court Name: Court of Appeals for the Eleventh Circuit
Date Published: Jun 20, 2017
Citation: 695 F. App'x 503
Docket Number: 16-16768 Non-Argument Calendar
Court Abbreviation: 11th Cir.