Smith v. Williams, 3:19-cv-00563

Plaintiff Jesse L. Smith, a Virginia inmate, alleged Eighth Amendment inadequate-medical-care claims under 42 U.S.C. § 1983 against LPN Chershondra Williams for delay in responding to an Offender Request concerning a urinary tract infection (UTI).
Smith submitted the Offender Request on Feb. 27, 2018; it reached the medical department on Mar. 6. The triage nurse position had been vacant; Williams became triage nurse around Mar. 19–20 and reviewed Smith's request on Mar. 20.
Williams replied on Mar. 20 that Smith "would be scheduled to see the doctor" and forwarded the request to the scheduling nurse; Smith was not seen by a physician until Apr. 24, 2018, by which time the infection had spread to bladder and kidneys.
Smith reported ongoing pain and weight loss; a June grievance review found the complaint "FOUNDED," noting care was delayed and he should have been seen sooner.
Williams contended she lacked authority to schedule or prioritize appointments and had no further involvement after forwarding the request; she also asserted limits of her LPN role.
The Court denied Williams' summary judgment motion (finding triable issues of deliberate indifference) but also denied Smith's motion for summary judgment because the record could support institutional or supervisory causation; the Court appointed counsel for Smith.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams acted with deliberate indifference by delaying/ not expediting care	Smith: three-week backlog + Williams' March 20 response and failure to ensure expedited scheduling caused harm when infection worsened	Williams: she forwarded the request to scheduler, lacked authority to set priorities or prescribe; acted reasonably	Denied Williams' summary judgment — a reasonable jury could find her failure to ensure prompt care rose to deliberate indifference
Whether Smith is entitled to summary judgment on Williams' liability	Smith: facts conclusively show liability for unconstitutional delay	Williams: record permits inference that systemic/supervisory failures caused delay, not her sole fault	Denied Smith's summary judgment — record not conclusive; institutional/supervisory culpability remains plausible

Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference requires subjective knowledge of and disregard of substantial risk)
Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (Eighth Amendment prohibits denial of adequate medical care for serious needs)
Iko v. Shreve, 535 F.3d 225 (4th Cir. 2008) (definition of a "serious" medical need)
Brown v. Harris, 240 F.3d 383 (4th Cir. 2001) (deliberate indifference standard applied to prison medical care claims)
Natale v. Camden Cty. Corr. Facility, 318 F.3d 575 (3d Cir. 2003) (failure to create policies to address urgent medical needs can constitute deliberate indifference)
Glisson v. Indiana Dep't of Corr., 849 F.3d 372 (7th Cir. 2017) (institutional policies can produce systemic deliberate indifference separate from individual actors)
Parrish ex rel. Lee v. Cleveland, 372 F.3d 294 (4th Cir. 2004) (official must subjectively recognize risk and that actions are inappropriate in light of that risk)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (summary judgment allocation of burdens)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (standard for genuine dispute at summary judgment)