Coverdale v. Conley, 1:19-cv-00920

Background

Plaintiff Thomas Coverdale, an incarcerated person, sued Dr. David Conley under 42 U.S.C. § 1983 alleging deliberate indifference for failing to send him for immediate hernia surgery on October 30–31, 2017 and for providing inadequate overnight care in the prison infirmary.
Medical records from multiple clinicians documented that Coverdale was kept in the infirmary, observed overnight, and did not present as the extreme distress he described in his affidavit.
Defendant moved for summary judgment; Magistrate Judge Bowman recommended granting it, finding Coverdale’s account "blatantly contradicted" by the medical records and insufficient to show deliberate indifference.
Coverdale objected, arguing the magistrate improperly weighed credibility, that medical records could have been manipulated, and that his self‑serving affidavit raised genuine factual disputes.
The district court conducted de novo review, rejected Coverdale’s objections, held (1) the magistrate appropriately relied on medical records that plainly contradicted Coverdale’s testimony, and (2) even if his version were credited, it did not establish deliberate indifference as a matter of law.
Court granted Defendant’s motion for summary judgment and terminated the case.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the magistrate improperly made credibility determinations at summary judgment	Coverdale: medical records conflict with his testimony but could be fabricated; credibility disputes require jury resolution	Conley: records from multiple clinicians contradict Coverdale and no evidence of fabrication; Scott/Davis allow rejecting blatantly contradicted testimony	Court: Magistrate properly relied on medical records; Coverdale's account was blatantly contradicted so no reasonable juror could credit it
Whether medical records can be treated like video evidence under Scott v. Harris/Davis v. Gallagher	Coverdale: Scott should be limited to video; medical records are less reliable	Conley: Scott/Davis focus on whether record evidence blatantly contradicts testimony, not on medium; medical records are admissible record evidence	Court: Scott/Davis apply; medical records can defeat self‑serving testimony absent evidence they were forged
Whether Coverdale's lay assertion that the hernia was irreducible creates a triable issue	Coverdale: he felt it was irreducible on Oct. 30	Conley: Coverdale is not a medical expert; medical professionals documented reducibility or disagreement; difference of medical opinion is not deliberate indifference	Court: Lay opinion and disagreement over medical judgment do not establish subjective deliberate indifference
Whether any delay in surgery or overnight observation amounted to deliberate indifference	Coverdale: observation delayed surgery and caused harm	Conley: no verifying medical evidence of harm from any delay; observation is proper medical management	Court: Plaintiff offered no verifying evidence of detrimental effect from delay; delay/observation did not show deliberate indifference

Key Cases Cited

Scott v. Harris, 550 U.S. 372 (when record blatantly contradicts a party's version, court need not adopt that version at summary judgment)
Davis v. Gallagher, 951 F.3d 743 (6th Cir.) (self‑serving testimony that is blatantly false may not create genuine issue)
Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment deliberate indifference standard requires subjective knowledge of substantial risk)
Estelle v. Gamble, 429 U.S. 97 (medical malpractice or disagreement over treatment is not Eighth Amendment violation)
Celotex Corp. v. Catrett, 477 U.S. 317 (movant meets summary judgment burden by showing lack of evidence for essential element)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standards and reasonable jury inquiry)
Comstock v. McCrary, 273 F.3d 693 (6th Cir.) (deliberate indifference requires objective and subjective components)
Napier v. Madison Cnty., 238 F.3d 739 (6th Cir.) (delay claim requires verifying medical evidence of harm)
Coble v. City of White House, Tenn., 634 F.3d 865 (6th Cir.) (focus on record evidence rather than medium when assessing blatantly contradicted testimony)
Gresham v. Meden, 938 F.3d 847 (6th Cir.) (observing that most litigation statements are self‑serving and are evaluated by evidence at summary judgment)
Alspaugh v. McConnell, 643 F.3d 162 (6th Cir.) (courts reluctant to second‑guess medical judgments in prison context)