Reilly v. Vadlamudi
2012 U.S. App. LEXIS 10614
| 6th Cir. | 2012Background
- Plaintiff Joshua Reilly, a prisoner, sues Dr. Seetha Vadlamudi and nurses Phillip Payne and Terry Smith for Eighth Amendment deliberate indifference and Michigan medical malpractice.
- Plaintiff alleges chronic left-eye headaches and swelling; in 2007–2008 he is later diagnosed with Ewing's Sarcoma after release from prison.
- Defendants moved for judgment on the pleadings claiming immunity; district court denied the motion finding plausibility of deliberate indifference and malpractice.
- The appeal targets Dr. Vadlamudi and Payne; Nurse Smith did not join the appeal.
- Court reverses and remands to enter judgment in favor of Vadlamudi and Payne, concluding no Eighth Amendment violation or gross negligence proven
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Vadlamudi's conduct violated the Eighth Amendment | Reilly asserts deliberate indifference existed | Vadlamudi had minimal contact and no knowledge of serious risk | No Eighth Amendment violation; immunity for Vadlamudi affirmed |
| Whether Payne's conduct violated the Eighth Amendment | Reilly asserts deliberate indifference and failure to refer | Payne's actions included a referral to an optometrist, not deliberate indifference | No Eighth Amendment violation; immunity for Payne affirmed |
| Whether Michigan's gross negligence immunity shielded the defendants | Reilly contends conduct was grossly negligent proximately causing injuries | Conduct did not amount to gross negligence; qualified immunity applies | Qualified immunity affirmed; judgment entered for Vadlamudi and Payne |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (medical care rights; deliberate indifference standard)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (objective seriousness and subjective awareness standard)
- Blackmore v. Kalamazoo County, 390 F.3d 890 (6th Cir. 2004) (deliberate indifference requires awareness of substantial risk)
- Sanderfer v. Nichols, 62 F.3d 151 (6th Cir. 1995) (awareness of risk and deliberate indifference analysis)
- Jones v. Muskegon County, 625 F.3d 935 (6th Cir. 2010) (cancer as a serious medical need under Eighth Amendment)
- Heyne v. Metro. Nashville Pub. Sch., 655 F.3d 556 (6th Cir. 2011) (individual liability required for each defendant)
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (modifies Saucier two-step approach to qualified immunity)
- McElligott v. Foley, 182 F.3d 1248 (11th Cir. 1999) (distinction between negligence and deliberate indifference in medical context)