Jamar Wilson v. Byanahak Jin
698 F. App'x 667
| 3rd Cir. | 2017Background
- Plaintiff Jamar Wilson, a state prisoner, sued under 42 U.S.C. § 1983 and state tort law claiming inadequate medical care after an inmate-on-inmate assault on Sept. 20, 2014 left him with a fractured arm. Defendants: prison officials (Commonwealth defendants) and treating physicians (medical defendants).
- Medical records show repeated medical attention: immediate nursing assessment, nurse advice to ice/elevate and submit sick-call, Dr. Park ordered x-rays and pain meds on Sept. 22, 2014, and Dr. Jin (board-certified general surgeon) performed a closed reduction, applied casts, ordered follow-up x-rays and physical therapy with documented progressive healing.
- Procedurally: both groups moved for summary judgment; the Magistrate Judge recommended granting both motions; the District Court adopted the recommendation; Wilson appealed. The Third Circuit summarily affirmed.
- Claims against Commonwealth defendants: denial of access to care, failure to intervene, and intentional infliction of emotional distress based on alleged misleading grievance responses and administrative handling.
- Claims against medical defendants: Eighth Amendment deliberate indifference, equal protection (denial of orthopedic consult due to RHU status), medical assault/battery (alleged nonconsensual "snapping" of bone), and intentional infliction of emotional distress.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eighth Amendment deliberate indifference (Commonwealth defendants) | Prison staff denied or delayed necessary care and deferred improperly to medical staff | Staff relied on medical staff instructions; plaintiff received nursing assessments and was told to submit sick-call | Summary judgment for defendants: no deliberate indifference; treatment occurred and non-medical staff could defer to medical judgment |
| Deliberate indifference (medical defendants) | Doctors failed to provide emergency specialist care, and treatment choices (including manual reduction) were constitutionally inadequate | Doctors ordered x-rays, reduced fracture, casted, followed up, and treatment succeeded; dispute is over adequacy not total denial | Summary judgment for defendants: care provided; disagreements/possible malpractice do not rise to Eighth Amendment violation |
| Equal Protection (denial of ortho consult due to RHU status) | Dr. Jin refused orthopedics because Wilson was in RHU, treating him differently from general population inmates | RHU inmates are not similarly situated; security/penological reasons justify differential treatment | Summary judgment for defendants: no equal protection violation; differential treatment had rational penological basis |
| State-law medical battery and IIED claims (medical defendants) | Closed reduction was performed without consent and caused pain/residual injury; conduct was outrageous | Closed reduction is a non-surgical procedure (no incision/excision/surgical instruments); not the kind of procedure requiring informed consent; conduct not extreme/outrageous given continuous care | Summary judgment for defendants: no medical battery (closed reduction not surgical); IIED fails — conduct not outrageous and physical harm/extreme conduct not established |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference standard)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (genuine dispute/summary judgment standard)
- Rouse v. Plantier, 182 F.3d 192 (deliberate indifference includes delay for non-medical reasons)
- Spruill v. Gillis, 372 F.3d 218 (prison officials may defer to medical staff; adequacy v. access distinction)
- Turner v. Safley, 482 U.S. 78 (prison regulation review; rational relation to penological interests)
- Cooper ex rel. Cooper v. Lankenau Hosp., 51 A.3d 183 (Pennsylvania law on medical battery and informed consent)
- Monmouth Cty. Corr. Institutional Inmates v. Lanzaro, 834 F.2d 326 (visibility of injury to layperson in Eighth Amendment context)
- White v. Napoleon, 897 F.2d 103 (deliberate indifference characterized by persistence in treatment despite risk/ pain)