Paul Scinto, Sr. v. Warden Stansberry
841 F.3d 219
| 4th Cir. | 2016Background
- Paul Scinto, Sr., a former federal inmate with insulin-dependent diabetes and other conditions, sued Bureau of Prisons officials under Bivens for Eighth Amendment deliberate-indifference to medical needs arising from events at FPC Butner in 2005–2006.
- Defendants on appeal: Dr. Derick Phillip (treating physician), Patricia Stansberry (Warden), and Susan McClintock (Camp Administrator). District court granted summary judgment to defendants on all claims; Scinto appealed three Eighth Amendment claims.
- Three claims on appeal: (1) Dr. Phillip denied prescribed supplemental insulin when Scinto requested it (June 14, 2005); (2) Dr. Phillip and McClintock failed to provide aid during an August 24, 2005 medical emergency (vomiting blood, severe pain) and instead placed Scinto in Special Housing Unit; (3) Warden Stansberry failed to provide a diabetic diet during six months in segregation.
- Evidence for claims: medical records showing increased blood glucose and A1C (≈7 to 9.8 from Jan–Sept 2005), contemporaneous cop-outs requesting insulin, testimony that emergency responders observed visible signs of serious illness, and Warden admissions that no special diet was provided in SHU but inmates were instructed how to choose from the general menu.
- Procedural outcome on appeal: Fourth Circuit reversed in part — allowed claims versus Dr. Phillip and Administrator McClintock to proceed (including denying qualified immunity), but affirmed dismissal as to Warden Stansberry’s diet claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of supplemental insulin violated Eighth Amendment | Scinto: withholding prescribed insulin and failing to follow monitoring/meal-coverage plan created serious risk and deliberate indifference (supported by A1C rise and cop-outs). | Phillip: refusal was reasonable because Scinto was angry/hostile; alternative monitoring/meal‑coverage plan was appropriate; expert proof required to show serious harm. | Reversed district court; triable issues exist on objective (seriousness) and subjective (deliberate indifference) prongs; no expert required; claim proceeds. |
| Whether Dr. Phillip and Administrator McClintock’s response to August 24 emergency amounted to deliberate indifference | Scinto: he exhibited obvious, severe symptoms (vomiting blood, incontinence, extreme pain); defendants observed and failed to provide aid, creating substantial risk of harm. | Defendants: followed protocol (incident report/administrative detention); dispute over why emergency phone was used; credibility favors officials. | Reversed district court; genuine disputes of material fact exist on both objective seriousness and subjective awareness/inference of risk; claim proceeds. |
| Whether Warden Stansberry’s failure to provide a diabetic diet in SHU violated Eighth Amendment | Scinto: lack of diabetic meals caused glucose/A1C spikes and hypoglycemic/hyperglycemic episodes. | Stansberry: no special diet in SHU but inmates educated how to choose acceptable foods; medical care (insulin adjustments) provided. | Affirmed for Stansberry. Court held plaintiff failed to show an "extreme deprivation"—no evidence he could not maintain health on available menu or that instruction was inadequate. |
| Whether Dr. Phillip and McClintock are entitled to qualified immunity | Scinto: right to adequate medical care and freedom from deliberate indifference was clearly established; disputed facts preclude immunity. | Defendants: argue right should be narrowly framed (e.g., single missed insulin dose to an angry inmate, or following protocol in placing inmate in detention) and thus not clearly established. | Denied qualified immunity. Court defined right broadly (adequate medical care / no deliberate indifference) and held it was clearly established; genuine factual disputes preclude immunity at summary judgment. |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to serious medical needs violates Eighth Amendment)
- Farmer v. Brennan, 511 U.S. 825 (1994) (two‑prong test: objective seriousness and subjective deliberate indifference)
- Wilson v. Seiter, 501 U.S. 294 (1991) (definition of "sufficiently serious" deprivation in conditions cases)
- De' Lonta v. Angelone, 330 F.3d 630 (4th Cir. 2003) (objective prong standards for Eighth Amendment conditions claims)
- Iko v. Shreve, 535 F.3d 225 (4th Cir. 2008) (medical‑needs deliberate‑indifference framework; right to adequate medical care)
- Parrish ex rel. Lee v. Cleveland, 372 F.3d 294 (4th Cir. 2004) (prima facie deliberate‑indifference where risk is longstanding, pervasive, or well‑documented)
- Miltier v. Beorn, 896 F.2d 848 (4th Cir. 1990) (failure to respond to known medical needs raises inference of deliberate indifference)
- Lolli v. County of Orange, 351 F.3d 410 (9th Cir. 2003) (denying insulin to a diabetic creates objective risk of harm)
- Hope v. Pelzer, 536 U.S. 730 (2002) (clarifies clearly established right standard for qualified immunity)
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity standard)
- Saucier v. Katz, 533 U.S. 194 (2001) (qualified immunity inquiry: constitutional violation and clearly established right)
- Pearson v. Callahan, 555 U.S. 223 (2009) (permits courts to decide qualified immunity steps in flexible order)