Robert Mitchell v. Damon Hininger, 553 F. App'x 602

Mitchell, an inmate, slipped on concrete stairs in March 2009 and later claimed ongoing back/hip pain.
Over 31 months, Mitchell underwent extensive tests, MRIs, medications and off-site orthopedic evaluations, leading to October 2011 back surgery.
Mitchell alleged deliberate indifference to a serious spinal condition in violation of the Eighth (and Fourteenth) Amendment; district court granted summary judgment for defendants.
Medical records show escalating treatment from analgesics to imaging and specialist referrals, culminating in surgery, with no outright denial of care.
Defendants included Corrections Corporation of America, warden, health services administrator, and safety supervisors; supervisory defendants argued lack of personal involvement.
The Sixth Circuit affirmed, holding no deliberate indifference by any individual defendant or policy, and upheld summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether treatment amounts to deliberate indifference	Mitchell.Longstanding pain treated inconsistently; delays indicate indifference.	Medical care escalated appropriately; no evidence of reckless disregard.	No deliberate indifference established
Whether supervisory defendants can be liable for deliberate indifference	Hininger, Pritchard, Lindamood, Steadman knew or should have corrected care delays.	Lay officials rely on medical judgment; no active unconstitutional conduct by supervisors.	No supervisory liability
Whether denial of administrative grievances supports § 1983 liability	Warden Lindamood approved grievance denial despite care deficiencies.	Grievance denial alone does not show deliberate indifference.	Not liable on this basis
Whether evidence shows a policy or custom of inadequate care by the facility	The facility's policy/custom caused harm through neglect.	No evidence of a policy causing deliberate indifference; individual errors do not prove policy.	No policy/custom liability

Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (deliberate indifference standard for medical needs)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (risk interpretation of deliberate indifference)
Alspaugh v. McConnell, 643 F.3d 162 (6th Cir. 2011) (inadequate care may still be no deliberate indifference)
Rhinehart v. Scutt, 509 F. App’x 510 (6th Cir. 2013) (contrasting degrees of medical treatment; disagreements not equal to indifference)
Graham v. County of Washtenaw, 358 F.3d 377 (6th Cir. 2004) (mere disagreement over treatment is not deliberate indifference)
Comstock v. McCrary, 273 F.3d 693 (6th Cir. 2001) (care provided, even if incompetent, does not equal deliberate indifference)
Spears v. Ruth, 589 F.3d 249 (6th Cir. 2009) (officials may rely on medical judgments)
Shehee v. Luttrell, 199 F.3d 295 (6th Cir. 1999) (grievance denial alone does not create § 1983 liability)
Brooks v. Celeste, 39 F.3d 125 (6th Cir. 1994) (negligence recidivist evidence does not prove indifference)
Olson v. Stotts, 9 F.3d 1475 (10th Cir. 1993) (long course of treatment does not show deliberate indifference)
Westlake v. Lucas, 537 F.2d 857 (6th Cir. 1976) (distinction between inadequate care and deliberate indifference)
City of Los Angeles v. Heller, 475 U.S. 796 (U.S. 1986) (government liability standards in § 1983 actions)