Steverson v. Dixon
8:22-cv-01462
| M.D. Fla. | Jul 16, 2025Background
- Plaintiff Bobby L. Steverson, an inmate at Hardee Correctional Institution, experienced a protracted dental issue that included pain, swelling, and a persistent infection after a tooth extraction.
- Steverson repeatedly sought treatment from Dr. Dwayne Miller (dentist) and Nurse Ashley Uney, receiving various medications, antibiotics, infirmary stays, and a CT scan.
- Plaintiff complained of delays in receiving an oral surgeon referral and anti-inflammatory medication after symptoms persisted, filing multiple grievances.
- Medical staff continuously monitored, prescribed treatments, and documented periods of improvement and worsening symptoms over a period of several months.
- After 90 days, Plaintiff was referred to and seen by an oral surgeon, who prescribed similar conservative treatments.
- Steverson filed suit under the Eighth Amendment for deliberate indifference to his medical needs; the case proceeded to summary judgment against Dr. Miller and Nurse Uney individually.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference by Nurse Uney | Uney delayed/denied pain meds, referrals | Uney responded reasonably, sought advice, no power to override doctors | No deliberate indifference; summary judgment for Uney |
| Deliberate indifference by Dr. Miller | Miller delayed oral surgeon referral, withheld anti-inflammatories | Miller closely monitored, saw improvements, referred to specialist when needed | No deliberate indifference; summary judgment for Miller |
| Delay in specialist referral caused harm | Delay worsened condition; needed prompt surgery | Delays justified by symptoms; similar treatment by specialist | No evidence delay exacerbated injury |
| Withholding anti-inflammatory | Miller said anti-inflammatory was needed but did not provide | No indication withholding posed serious risk | No evidence of harm or recklessness; no liability |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (establishes deliberate indifference to serious medical needs as Eighth Amendment violation)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires subjective recklessness)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (standard for summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (burden of proof at summary judgment)
- Farrow v. West, 320 F.3d 1235 (11th Cir. 2003) (objective and subjective prongs for deliberate indifference)
- Goebert v. Lee Cty., 510 F.3d 1312 (11th Cir. 2007) (plaintiff must show defendant's conduct caused injury)
- Taylor v. Adams, 221 F.3d 1254 (11th Cir. 2000) (delay must detrimentally exacerbate medical problem to be actionable)