Case Result: Medical Professionals Vindicated After Being Sued for Indifference to Medical Needs

Professionals:
Physicians 

Primary Issue:
Plaintiffs sued a prison medical provider and a utilization management physician, alleging deliberate indifference to serious medical needs.

Facts:
Plaintiff’s decedent suffered from end-stage liver disease (ESLD) and several related complications of the disease. Several years after failing Hepatitis C treatment, decedent developed esophageal varices that required ligation banding on two separate occasions. Decedent also wanted a liver transplant and a transjugular intrahepatic portosystemic shunt (TIPS). Decedent subsequently died as a result of complications from hip surgery.

Procedural history:
After the decedent’s death, his family (Plaintiffs) alleged the medical provider failed to order follow-up specialist referrals to monitor the decedent’s ESLD. Further, Plaintiffs contended that the utilization management physician unreasonably denied referrals for consideration of a liver transplant and TIPS placement. Plaintiffs did not allege any wrongdoing in connection with the hip surgery and the decedent’s death.

The trial court identified several questions of fact for a jury to decide, but it later granted summary judgment based on new legal authority from the 6th U.S. Circuit Court of Appeals (Mattox v. Edelman) and de bene esse depositions. Plaintiffs appealed to the 6th Circuit, arguing that the trial court failed to draw inferences in favor of the Plaintiffs and applied the wrong legal standards to their claims.

Result:
A majority of the 6th Circuit panel affirmed the trial court’s judgment in a 40-page opinion marked for publication. The opinion created new precedent on the issue of medical needs that are diagnosed by a physician and thereby mandate treatment. Specifically, the majority found that the defendant doctors were not deliberately indifferent under the court’s new test because their medical judgment was reasonable and did not demonstrate the level of obduracy and wantonness required to prove a constitutional violation.

In addition to vindicating our clients, the majority’s opinion brings clarity to a complex issue that will benefit correctional medical providers throughout the 6th Circuit for years to come.

Areas of Law:
Correctional Healthcare
42 USC § 1983 — Deliberate Indifference

Disclaimer:
This information is a sample of our past results. Prospective clients may not obtain the same or similar results. Every case is different and each case must be evaluated and handled on its own merits. The circumstances of your case may differ from the results provided. The information provided has not been reviewed or approved by the State Bar.