History
  • No items yet
midpage
Francis Brauner v. Shirley Coody
2015 U.S. App. LEXIS 12390
| 5th Cir. | 2015
Read the full case

Background

  • 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)
Read the full case

Case Details

Case Name: Francis Brauner v. Shirley Coody
Court Name: Court of Appeals for the Fifth Circuit
Date Published: Jul 17, 2015
Citation: 2015 U.S. App. LEXIS 12390
Docket Number: 14-30801
Court Abbreviation: 5th Cir.