William Lane v. Wexford Health Sources
510 F. App'x 385
| 6th Cir. | 2013Background
- Lane, a pro se Ohio prisoner, sues Wexford Health Sources and two prison staff for deliberate indifference under §1983.
- Lawsuit seeks monetary and injunctive relief based on arthritis, a leg injury, and leg-length discrepancy.
- Allegations include inadequate low-level dorm accommodation, receipt of defective footwear, and delayed medical care after injuries in 2009–2010; Sawyer a hospital administrator is named.
- District court granted summary judgment to Wexford and Redden; Sawyer was later dismissed; Lane’s appeal challenged those dismissals.
- Lane’s notice of appeal premised on incomplete record; the court held only Wexford and Redden rulings were properly before the appellate court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wexford defendants are liable under §1983 | Lane argues Wexford failed to ensure proper medical care. | Wexford liability requires policy or custom; mere medical negligence not enough. | Affirmed: no §1983 claim against Wexford |
| Whether Redden's conduct showed deliberate indifference | Redden ignored or inadequately treated serious medical needs. | Record shows medical staff attempted to manage care; no deliberate indifference. | Affirmed: no deliberate-indifference by Redden |
| Whether Lane's appeal was proper given the partial finality and record | Challenge to all three defendants should be reviewable on appeal. | Appeal premature; Sawyer dismissal not final at time of notice; only Wexford/Redden review is proper. | Appeal limited to Wexford and Redden; Sawyer issues not before court |
Key Cases Cited
- Williams v. Mehra, 186 F.3d 685 (6th Cir. 1999) (de novo review of district court judgments)
- Johnson v. Karnes, 398 F.3d 868 (6th Cir. 2005) (§1983 liability requires policy or custom, not respondeat superior)
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (deliberate indifference standard for medical care)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (high standard of intent in deliberate indifference claim)
- Miller v. Calhoun Cnty., 408 F.3d 803 (6th Cir. 2005) (deliberate indifference requires more than negligent treatment)
- Bellamy v. Bradley, 729 F.2d 416 (6th Cir. 1984) (personal involvement requirements in §1983 claims)
- Vance ex rel. Hammons v. United States, 90 F.3d 1145 (6th Cir. 1996) (Rule 56(d) discovery preservation concerns in summary judgment)
- Summers v. Leis, 368 F.3d 881 (6th Cir. 2004) (bare discovery allegations insufficient under Rule 56(d))
- Plott v. Gen. Motors Corp., Packard Elec. Div., 71 F.3d 1190 (6th Cir. 1995) (Rule 56(d) requirements to preserve discovery argument)
- Bonner v. Perry, 564 F.3d 424 (6th Cir. 2009) (jurisdictional scope on appeal from partial final judgments)