Franklin R. Harris v. William Neilds
706 F. App'x 945
| 11th Cir. | 2017Background
- On April 9, 2010, inmate Franklin Harris fell while being transferred between prison vans; he is a 67‑year‑old wheelchair user with preexisting degenerative cervical spine disease.
- After the fall Harris complained of head, neck, wrist pain, dizziness, impaired vision, and had a visible hematoma above his right eyebrow; officers took him to the prison system hospital ER.
- Dr. William Nields (ER physician) examined Harris, found him alert with a small hematoma, gave Tylenol, and decided no emergency imaging (x‑ray/MRI) was medically necessary; Harris was told to use sick call if symptoms persisted.
- Back at the prison medical unit, Nurse James Bunting initially told Harris to return to his dormitory and sign up for sick call, later took vitals and documented a normal neurological status and a 20mm hematoma.
- Harris’s condition prompted sick call on April 12, x‑rays on April 13 (skull, right hand, right forearm normal; cervical x‑ray showed chronic C6‑7 changes), and an MRI in May showing degenerative disc disease and nerve involvement; Harris sued Nields and Bunting under § 1983 for Eighth Amendment deliberate indifference to medical needs.
- The district court granted summary judgment to both defendants (finding no serious medical need and mere medical disagreement); the Eleventh Circuit AFFIRMED as to both defendants, though it held the record could create a jury issue on seriousness of need but found no deliberate indifference or causation as to the two providers.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Harris had a "serious medical need" on April 9 | Harris: visible hematoma, pain, dizziness, numbness, impaired vision and worsening symptoms created a serious need | Defendants: injuries were minor swelling/bruise; ER exam normal so no emergency care required | Court: disputed fact exists; viewing evidence for Harris, a jury question exists on seriousness (district court erred on this point) |
| Deliberate indifference by Dr. Nields (failure to order imaging/diagnose) | Harris: Nields failed to order x‑rays/MRI and misdiagnosed, delaying care | Nields: performed ER evaluation, gave pain medication, reasonably concluded no emergency imaging needed; later tests confirmed that immediate imaging was unnecessary | Held: summary judgment for Nields affirmed; medical judgment not deliberate indifference |
| Deliberate indifference by Nurse Bunting (refusal/treatment delay/threats) | Harris: Bunting refused emergency referral, threatened confinement, walked away, gave only vitals | Bunting: Harris had been seen in ER; directed sick‑call appropriately, later examined and documented normal neuro status | Held: no evidence that Bunting caused harm; even assuming delay, no causation shown — summary judgment affirmed |
| Causation from any alleged delay (harm from four‑day wait for imaging) | Harris: delay caused suffering, fear of concussion, and possibly worsened condition | Defendants: later x‑rays/MRI showed chronic conditions; immediate imaging would not have changed treatment or healed hematoma | Held: no causal link between defendants’ conduct and Harris’s injuries; delay did not produce actionable harm |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference standard)
- Farmer v. Brennan, 511 U.S. 825 (subjective intent requirement for deliberate indifference)
- McElligott v. Foley, 182 F.3d 1248 (Eleventh Circuit on objective/subjective components and medical care)
- Melton v. Abston, 841 F.3d 1207 (discussing degree of culpability and serious medical need examples)