Samuel Jackson v. Joseph Lightsey, 775 F.3d 170

Plaintiff Samuel Jackson, incarcerated since 2008, alleges preexisting congestive heart failure treated successfully before incarceration; after intake, prison medical changes allegedly worsened his condition, culminating in a heart attack.
Jackson sued two prison physicians (Lightsey and Guleria) and the Department of Corrections medical Staff under 42 U.S.C. § 1983 for Eighth Amendment deliberate indifference.
District court dismissed the Staff sua sponte in a 2012 order under § 1915A and later granted defendants’ Rule 12(b)(6) motion in a 2013 order, dismissing claims against the doctors and entering final judgment.
Jackson filed a pro se notice of appeal referencing only the July 31, 2013 order; the Fourth Circuit clerk treated it as an appeal here, appointed counsel, and the appeal proceeded.
Fourth Circuit held it lacked jurisdiction to review the 2012 dismissal of the Staff because Jackson’s notice expressly designated only the 2013 order and the Staff received no notice or opportunity to brief the appeal.
On the merits, the court affirmed dismissal as to Lightsey (medical disagreement) but vacated and remanded the dismissal as to Guleria, finding Jackson’s allegations of promised but unentered orders sufficient to state a plausible deliberate-indifference claim at the 12(b)(6) stage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of notice of appeal naming the appellate court	Omission of words "Fourth Circuit" is immaterial; intent to appeal is clear	Rule 3(c) requires naming the court; omission is fatal	Notice sufficiently indicated appeal to Fourth Circuit; liberal construction applied (Rule 3(c)(1)(C) satisfied)
Whether appeal includes 2012 order dismissing Staff	Jackson later argued Staff dismissal should be reviewed	Appellees argued the notice designated only the 2013 order; Staff had no notice or chance to brief	No jurisdiction to review 2012 order; appeal limited to 2013 order and claims addressed therein
Deliberate indifference claim against Lightsey	Lightsey misdiagnosed and changed cardiologist’s meds, causing harm	Defendants: allegations, at most, plead medical disagreement or malpractice, not constitutional violation	Affirmed dismissal as to Lightsey: allegations show disagreement over care, insufficient for Eighth Amendment claim
Deliberate indifference claim against Guleria	Guleria ordered tests/treatment but failed to enter orders or ensure treatment, leaving plaintiff untreated	Defendants: failure to state subjective deliberate indifference as required by Farmer	Vacated dismissal as to Guleria: allegations plausibly show subjective knowledge of need and failure to provide ordered care; claim survives 12(b)(6)

Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference framework)
Farmer v. Brennan, 511 U.S. 825 (subjective knowledge standard for deliberate indifference)
Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for complaints)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading standard)
Miltier v. Beorn, 896 F.2d 848 (treating physician’s failure to provide care he deemed necessary can show deliberate indifference)
Summers v. Altarum Inst., Corp., 740 F.3d 325 (standard of review on Rule 12(b)(6) appeal)
In re Spence, 541 F.3d 538 (liberal/flexible approach to Rule 3 notice requirements)