Daniel Scott v. Mary Benson
2014 U.S. App. LEXIS 2084
| 8th Cir. | 2014Background
- Scott, an involuntarily committed CCUSO patient, sues Benson under 42 U.S.C. § 1983 for constitutionally deficient medical care.
- The district court denied Benson’s summary judgment motion based on qualified immunity.
- Facts from Aug.–Sept. 2010 are disputed: Scott allegedly developed severe infections; Benson reportedly downplayed symptoms and delayed treatment.
- Scott alleges belittlement and failure to diagnose/treat, leading to hospitalization, heart attack, sepsis, and later amputation.
- Benson moved for summary judgment; Scott filed a competing affidavit that altered timing and details of events.
- The Eighth Circuit vacates the district court’s denial, holding the wrong constitutional standard was used and remands for application of the deliberate indifference standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which constitutional standard applies? | Scott argues deliberate indifference governs medical care claims. | Benson argues a professional-judgment standard applies. | Deliberate indifference standard governs. |
| Was the district court's choice of standard correct? | Scott contends the district court used the wrong standard. | Benson contends the chosen standard was correct. | District court used the wrong standard; remand required. |
| Should the case be remanded for a full qualified-immunity analysis under the correct standard? | Scott seeks remand for proper analysis under deliberate indifference. | Benson seeks resolution under the asserted standard. | Remanded to conduct full analysis under deliberate indifference. |
Key Cases Cited
- Krout v. Goemmer, 583 F.3d 557 (8th Cir. 2009) (interlocutory appeal of qualified immunity where denial is reviewed de novo)
- Johnson v. Jones, 515 U.S. 304 (Supreme Court 1995) (collateral order doctrine and qualified-immunity interlocutory appeal)
- Senty-Haugen v. Goodno, 462 F.3d 876 (8th Cir. 2006) (deliberate indifference standard for medical care in Fourteenth Amendment context)
- Cruzan by Cruzan v. Dir., Mo. Dep’t of Health, 497 U.S. 261 (Supreme Court 1990) (Youngberg does not control decisions to administer/withhold medical treatment)
- Meuir v. Greene Cnty. Jail Emps., 487 F.3d 1115 (8th Cir. 2007) (deliberate indifference is a fact-intensive inquiry with objective and subjective prongs)
- Handt v. Lynch, 681 F.3d 939 (8th Cir. 2012) (remand when district court’s analysis inadequately addresses individual actions)
- Santiago v. Blair, 707 F.3d 984 (8th Cir. 2013) (remand where district court applied an incorrect constitutional standard)