Francis Brauner v. Shirley Coody
2015 U.S. App. LEXIS 12390
| 5th Cir. | 2015Background
- Brauner is a paraplegic inmate at Louisiana State Penitentiary with chronic pressure ulcers and osteomyelitis.
- Defendants include Assistant Wardens Shirley Coody and Kenneth Norris and doctors Jonathan Roundtree, Jason Collins, and David Hal McMurdo.
- Prison staff treated Brauner since January 2011; his condition was known and significant.
- Brauner alleges deliberate indifference to serious medical needs under the Eighth Amendment; the district court denied qualified immunity, which the Fifth Circuit reversed.
- The court held the record does not support deliberate indifference and granted judgment for the defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Brauner shows deliberate indifference under the Eighth Amendment. | Brauner shows persistent, unreasonable neglect of care. | Doctors and wardens provided medical treatment and oversight. | No; record shows no deliberate indifference. |
| Whether the district court properly denied qualified immunity given the record. | Qualified immunity should be denied due to disputed facts. | No genuine issues of material fact; actions were reasonable. | Yes; qualified immunity applies. |
| Whether supervisory liability can attach for wound-care concerns. | Wardens failed to supervise subordinates adequately. | Doctors controlled treatment; no deliberate indifference by supervisors. | Not viable; no evidence of supervisor deliberate indifference. |
Key Cases Cited
- Gobert v. Caldwell, 463 F.3d 339 (5th Cir. 2006) (negligence present, but not deliberate indifference when records show continued care)
- Stewart v. Murphy, 174 F.3d 530 (5th Cir. 1999) (negligence not equal to deliberate indifference in pressure-sore cases)
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (deliberate indifference requires serious medical need awareness and disregard)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference standard; high bar for prison officials)
