Stewart v. Pennsylvania Department of Corrections
677 F. App'x 816
| 3rd Cir. | 2017Background
- Stewart, a Pennsylvania inmate, sued prison medical staff and supervisors under 42 U.S.C. § 1983 alleging inadequate care for a left ankle injury sustained playing basketball in July 2012.
- Initial treatment diagnosed a sprain (ice, wrap, crutches); subsequent X-rays and visits later revealed an acute fracture and the ankle was casted and treated by PA Leahy and Dr. Naji; multiple follow-ups, x‑rays, PT, and antifungal treatments occurred through 2013.
- Stewart alleged a delayed diagnosis (five days without treatment after a misdiagnosis) and ongoing pain; he named supervisory officials and Corizon (the contractor) as defendants as well as treating medical personnel.
- District Court dismissed several supervisors and Corizon for lack of personal involvement and later granted summary judgment to the Medical Defendants, concluding treatment was adequate and not deliberately indifferent.
- Stewart appealed pro se; the Third Circuit summarily affirmed, finding no substantial question presented.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether supervisors (Glunt, Younkin, Corizon CEO) are liable for Eighth Amendment deliberate indifference | Supervisors failed to intervene, denied MRI, ignored pain complaints | Supervisors lacked personal involvement in medical decisions; no underlying constitutional violation by subordinates | Dismissed: supervisory liability requires personal involvement or underlying constitutional violation; mere failure to intervene not actionable |
| Whether medical staff were deliberately indifferent by misdiagnosing fracture and delaying treatment | Misdiagnosis and a five‑day gap caused continued pain and delayed fracture care, showing indifference | Medical staff provided numerous evaluations, x‑rays, casts, PT, and meds; disagreement or malpractice not Eighth Amendment violation | Summary judgment for medical defendants: evidence showed prompt, substantial care; misdiagnosis/ delay at most malpractice, not deliberate indifference |
| Whether the five‑day period of no treatment after misdiagnosis satisfies subjective awareness element | Stewart contends staff should have known fracture severity during gap | Record shows staff reasonably believed injury was a sprain based on X‑rays; no evidence they actually knew of the fracture during that period | Held: plaintiff did not show defendants knew of and disregarded excessive risk; negligence or should‑have‑perceived risk insufficient |
| Whether plaintiff produced sufficient evidence to avoid summary judgment | Stewart points to requests for care, pain, and delayed fracture diagnosis | Defendants cite extensive treatment record (evaluations, consults, x‑rays, meds, PT) and lack of evidence of deliberate indifference | Summary judgment affirmed: no evidence beyond plaintiff’s assertions to show subjective deliberate indifference |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (standards for pleading plausibility)
- Farmer v. Brennan, 511 U.S. 825 (subjective knowledge requirement for Eighth Amendment deliberate indifference)
- Spruill v. Gillis, 372 F.3d 218 (limits on supervisory liability without personal knowledge or involvement)
- Kost v. Kozakiewicz, 1 F.3d 176 (medical malpractice does not equal constitutional violation)
- Monmouth Cty. Corr. Institutional Inmates v. Lanzaro, 834 F.2d 326 (what constitutes a serious medical need)
- Barkes v. First Corr. Med., Inc., 766 F.3d 307 (supervisory liability frameworks for prison medical claims)
- Fantone v. Latini, 780 F.3d 184 (pleading standard reference)
- Giles v. Kearney, 571 F.3d 318 (summary judgment standard review)
- Singletary v. Pa. Dep’t of Corr., 266 F.3d 186 (evidence requirement to defeat summary judgment on deliberate indifference)