Harold Crane v. Lifemark Hospitals, Inc., 898 F.3d 1130

Background

Harold Crane, a profoundly deaf patient with depression and anxiety, was taken to Palmetto General Hospital (PGH) under Florida's Baker Act for an involuntary examination after a suicidal report.
During his multi-day hospitalization (July 17–20, 2011) Crane repeatedly requested an ASL interpreter; hospital staff primarily relied on written notes and a doctor’s limited sign skills until an interpreter arrived on July 20, the day of discharge.
Dr. Marjorie Caro conducted the Baker Act evaluation, recorded that Crane could not fully understand the process via writing and had difficulty expressing himself, and later noted an interpreter was helpful on July 20.
Crane sued PGH and its parent under Section 504 of the Rehabilitation Act and Title III of the ADA, alleging failure to provide appropriate auxiliary aids and ineffective communication; he sought damages and injunctive relief.
The district court granted summary judgment for defendants, finding written notes/basic signing constituted effective communication and that staff were not deliberately indifferent; Crane appealed.
On de novo review, the Eleventh Circuit found genuine disputes of material fact on both (1) whether Crane had an equal opportunity to exchange medically relevant information and (2) whether the hospital acted with deliberate indifference, and reversed and remanded.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether hospital provided appropriate auxiliary aids to ensure effective communication about medically relevant information	Crane: written notes and basic signing were inadequate; he was hindered from explaining trauma and symptoms	Defendants: written notes and doctor’s basic signing satisfied the duty to ensure effective communication during Baker Act exam	Reversed: factual dispute exists whether communication was effective; jury must decide
Whether the hospital was deliberately indifferent (required for monetary damages)	Crane: staff knew communication was ineffective and failed to act despite likelihood of harm	Defendants: no evidence of disrespect or intentional discrimination; staff trained and had policies	Reversed: sufficient evidence of deliberate indifference to survive summary judgment
Proper focus of inquiry under ADA/RA	Crane: focus should be on patient's opportunity to exchange medically relevant information	Defendants: emphasis on meeting Baker Act procedural requirements and medical records showing evaluation occurred	Court: correct inquiry is Crane’s equal opportunity to exchange medically relevant information, not merely completion of statutory exam
Standard for summary judgment in effective-communication claims	Crane: fact-intensive inquiry usually precludes summary judgment	Defendants: record supports no genuine issue of material fact	Court: fact-intensive nature means summary judgment improper here due to competing evidence

Key Cases Cited

Silva v. Baptist Health S. Fla., Inc., 856 F.3d 824 (11th Cir. 2017) (defines effective-communication inquiry and standard under ADA/RA)
Liese v. Indian River Cty. Hosp. Dist., 701 F.3d 334 (11th Cir. 2012) (deliberate indifference standard for damages under RA/ADA)
Shotz v. Cates, 256 F.3d 1077 (11th Cir. 2001) (discrimination claim elements under ADA/RA)
McCullum v. Orlando Reg'l Healthcare Sys., Inc., 768 F.3d 1135 (11th Cir. 2014) (articulates deliberate indifference as knowledge of likely harm and failure to act)
Cash v. Smith, 231 F.3d 1301 (11th Cir. 2000) (ADA/RA substantive liability standard equivalence)
Feliciano v. City of Miami Beach, 707 F.3d 1244 (11th Cir. 2013) (nonmovant’s testimony credited over conflicting records on summary judgment)