Holton v. United States, 4:22-cv-00070

Plaintiff Ruben C. Holton, a former federal inmate, brought a pro se Federal Tort Claims Act (FTCA) suit against the United States, alleging inadequate medical treatment for COVID-19 symptoms during his incarceration at FCI Schuylkill in 2021.
Holton alleged he was denied proper testing and care for COVID-19, leading to his infection and subsequent prolonged symptoms, despite following prison instructions to report his symptoms.
After initial motions, the individual medical staff defendants were dismissed, leaving only the United States as a defendant.
The United States moved for judgment on the pleadings, arguing lack of causation between alleged negligence and Holton's injuries, and that the claims were not legally sufficient.
Two types of negligence claims were identified: medical malpractice (failure to test/treat) and ordinary negligence (failure to provide for safety and care).
The District Court addressed whether Holton’s claims sufficiently alleged causation for contracting COVID-19 and/or for his prolonged symptoms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does failure to test/treat for COVID-19 allow FTCA malpractice/ordinary negligence claims?	Holton: Defendants’ failures breached duty under both ordinary and professional negligence standards.	USA: Plaintiff failed to plead facts showing causation for COVID-19 infection, and failure to test can’t cause infection.	Plaintiff alleged sufficient facts for lingering symptoms, not for infection itself.
Is a Certificate of Merit (COM) required for FTCA medical malpractice claims?	Holton: COM not required in FTCA context.	USA: (Initially argued for dismissal based on lack of COM).	COM not required for FTCA claims.
Has Holton alleged sufficient causation between defendant’s breach and his contraction of COVID-19?	Defendants’ acts led directly to infection.	No plausible link; failure to test does not cause infection.	Plaintiff did not allege causation for infection; claims dismissed for this injury.
Has Holton alleged sufficient causation for prolonged/lingering symptoms resulting from delayed/deficient care?	Delay in treatment increased risk of lasting harm.	Physical/mental effects are part and parcel of infection itself.	Plaintiff alleged sufficient facts; claim may proceed.

Wilson v. United States, 79 F.4th 312 (3d Cir. 2023) (Certificate of Merit not required for FTCA medical malpractice claims)
Merlini ex rel. Merlini v. Gallitzin Water Auth., 980 A.2d 502 (Pa. 2009) (Sets out elements for negligence claims under Pennsylvania law)
Grossman v. Barke, 868 A.2d 561 (Pa. Super. Ct. 2005) (Defines professional negligence/medical malpractice standard in PA)
Rouse v. Plantier, 182 F.3d 192 (3d Cir. 1999) (Liability for delay or denial of medical care in prisons)
Natale v. Camden Cnty. Corr. Facility, 318 F.3d 575 (3d Cir. 2003) (Liability for inadequate medical care where need is evident)
Monmouth Cnty. Corr. Institutional Inmates v. Lanzaro, 834 F.2d 326 (3d Cir. 1987) (Injuries can arise from delay in necessary medical treatment)
Hamil v. Bashline, 392 A.2d 1280 (Pa. 1978) (Increased risk of harm standard for causation in negligence).