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Media Alerts - Scinto v. Stansberry -- Fourth Circuit
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February 23, 2017
  Scinto v. Stansberry -- Fourth Circuit
Federal Prisoner's Claims of Improper Medical Care Survive

Areas of Law: Constitutional Law, Eighth Amendment

Issue Presented: Whether the District Court in dismissing three Eighth Amendment claims improperly made credibility determinations and weighed the evidence.

Brief Summary: The United States Court of Appeals for the Fourth Circuit held that the United States District Court for District of North Carolina erred in dismissing two Eighth Amendment claims against Dr. Phillip and Administrator McClintock, two employees at the Federal Prison Camp Seymour Johnson. The Fourth Circuit held that Scinto's claim against Dr. Phillip for his denial of insulin and the claim against Administrator McClintock and Dr. Phillip for the failure to provide aid during a medical emergency fit the Supreme Court's two-pronged test in Farmer v. Brennan.

Extended Summary: Paul Scinto, a former federal prisoner, appealed to the Fourth Circuit to review the District Court of North Carolina's dismissal of three Eighth Amendment claims that Defendants Phillip, Stansberry, and McClintock were deliberately indifferent to his medical needs, in violation of the Eighth Amendment. Scinto argued that in dismissing these claims, the district court violated the summary judgment standard by making credibility determinations and weighing the parties' evidence.

The Fourth Circuit noted that when prisoners allege they have been subjected to unconstitutional conditions of confinement, they must satisfy the Supreme Court's two-pronged test in Farmer v. Brennan. The first prong of Farmer's test is an objective prong requiring plaintiffs to demonstrate that "the deprivation alleged [was], objectively "sufficiently serious." The deprivation itself must be "extreme." The second prong of Farmer is a subjective prong, requiring plaintiffs to show that prison officials acted with a "sufficiently culpable state of mind." In order to prove deliberate indifference, plaintiffs must show that "the official kn[ew] of and disregard[ed] an excessive risk to inmate health or safety." Importantly, the Fourth Circuit noted that a plaintiff could make out a prima facie case of deliberate difference by demonstrating "that a substantial risk of [serious harm] was longstanding, pervasive, well-documented, or expressly noted by prison officials[.]"

Regarding Scinto's first claim against Dr. Phillip for allegedly denying him insulin to treat his diabetes, the Fourth Circuit found the plaintiff provided sufficient evidence to establish a genuine dispute of fact as to Farmer's objective and subjective prongs. The court found Scinto did this because he established that he suffered from a serious medical condition and he created a genuine issue of material fact regarding whether Dr. Phillip's failure to provide him with insulin constituted an "extreme deprivation." Additionally, the Fourth Circuit found that plaintiff's lengthy prison medical records showed that his diabetes diagnosis was "longstanding, pervasive, and well-documented." Plaintiff's second claim arose out of Dr. Phillip's and Administrator McClintock's alleged failure to provide him aid during a medical emergency. Specifically, Plaintiff alleged that during a lockdown he experienced extreme stomach pain and began throwing up vomit and blood. The Fourth Circuit held that Plaintiff's evidence created a genuine dispute of fact as to whether the denial of medical attention during this emergency resulted in serious injury or a substantial risk of serious injury. The Fourth Circuit also held that Plaintiff's evidence established genuine disputes of material fact as to both Farmer prongs. Last, regarding Plaintiff's final claim against Warden Stansberry alleging a denial of a proper diabetic diet during his six-month confinement in the Special Housing Unit, the Fourth Circuit affirmed the district court's award of summary judgment for the claim, but not for the reason stated. Instead, the Fourth Circuit held that the Plaintiff failed to raise a genuine dispute of material fact regarding whether the lack of a diabetic diet was a sufficiently serious deprivation actionable under the Eighth Amendment.

In addressing the qualified immunity claims raised by the Defendants, the Fourth Circuit held the Defendant's allegedly violated a clearly established statutory or constitutional right -- a prisoner's right to adequate medical care and freedom from deliberate indifference to medical needs. In addition, the Fourth Circuit found there was sufficient evidence that Plaintiff's aforementioned Eighth Amendment right was violated and that the right was clearly established. Thus, Dr. Phillip and Adminstrator McClintock were not entitled to qualified immunity.

To view the full opinion, click here.

Panel: Judges Niemeyer, Motz, and Wynn

Argument Date: 09/23/2016

Date of Issued Opinion: 11/04/2016

Docket Number: No. 15-1587

Affirmed in part and reversed in part.

Case Alert Author: Dena Robinson, Univ. of Maryland Carey School of Law

Counsel: ARGUED: Adam H. Farra, COHEN MILSTEIN SELLERS & TOLL PLLC, Washington, D.C., for Appellant. Robert J. Dodson, OFFICE OF THE UNITED STATES ATTORNEY, Raleigh, North Carolina, for Appellees. ON BRIEF: Paul J. Zidlicky, SIDLEY AUSTIN LLP, Washington, D.C., for Appellant. John Stuart Bruce, Acting United States Attorney, G. Norman Acker, III, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Raleigh, North Carolina, for Appellees.
Author of Opinion: Judge Wynn

Case Alert Supervisor: Professor Renee Hutchins

    Posted By: Renee Hutchins @ 02/23/2017 03:51 PM     4th Circuit  

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