Christine Warren v. Prison Health Services, Inc., 576 F. App'x 545

Warren, an inmate at Newberry Correctional Facility, died of a heart attack on Jan 31, 2010 after weeks of chest-pain complaints and medical evaluation requests.
Nurse Shilling first noted chest pain on Jan 16 and scheduled a later doctor visit; Warren denied current pain.
Nurse Freytag on Jan 17-18 observed symptoms but deemed care routine and referred to a doctor for Jan 19.
Dr. Bomber evaluated Warren on Jan 18 and ordered a Cardiolite stress test; cardiology consultation was sought but delayed.
Dr. Edelman limited Cardiolite testing and suggested alternative stress tests; Warren’s requests for urgent testing remained unresolved for days.
On Jan 27-29, hospital-testing issues and administrative delays persisted; Warren’s condition deteriorated and he died on Jan 31 after not receiving timely stress testing or emergency care.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants acted with deliberate indifference to Warren’s serious medical needs.	Warren’s life-threatening symptoms and denying timely stress testing show knowledge of serious risk.	Treating clinicians exercised medical judgment and delays were not reckless disregard.	Material facts support deliberate indifference for Shilling and Bomber; others affirmed.
Whether Shilling and Bomber could be liable under Estelle even absent malice.	They knew or should have known of the risk and disregarded it.	No evidence of actual awareness or disregard of a substantial risk.	Summary judgment overturned for Shilling and Bomber; remanded for trial.
Whether PHS can be liable under Monell or as a state actor.	PHS policies and practices caused inadequate care.	PHS not sufficiently shown to be responsible for the alleged constitutional violation.	Court did not decide PHS liability on appeal; issue abandoned or unresolved.

Estelle v. Gamble, 429 F.2d 97 (U.S. 1976) (Eighth Amendment medical-care standard; deliberate indifference requires more than negligence)
Hope v. Pelzer, 536 U.S. 730 (U.S. 2002) (circumstantial inference of knowledge allowed to prove subjective awareness of risk)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference requires conscious disregard of known substantial risk)
Wilson v. Seiter, 501 U.S. 294 (U.S. 1991) (subjective component of deliberate-indifference standard)
Estate of Carter v. City of Detroit, 408 F.3d 305 (6th Cir. 2005) (circumstantial evidence supports inference of actual knowledge of risk)
Phillips v. Roane Cnty., Tenn., 534 F.3d 531 (6th Cir. 2008) (correctional officers’ conduct related to chest-pain/shortness of breath case)