Daniel J. Scott v. Mary Benson

Summary

The Eighth Circuit reviewed an interlocutory appeal from the denial of qualified immunity to a nurse practitioner accused of providing constitutionally deficient medical care to a civilly committed patient. The court held that the district court applied the wrong constitutional standard, concluding that the deliberate-indifference standard, rather than the professional-judgment standard from Youngberg v. Romeo, governs the patient's Fourteenth Amendment medical-care claim. The court vacated the denial of summary judgment and remanded for application of the deliberate-indifference standard.

Holdings

1. The collateral-order doctrine gives the Eighth Circuit limited authority to hear an interlocutory appeal from the denial of qualified immunity.
2. A Fourteenth Amendment claim by a civilly committed person alleging constitutionally deficient medical care is governed by the deliberate-indifference standard applicable under the Eighth Amendment, not the professional-judgment standard from Youngberg v. Romeo.
3. To establish deliberate indifference to a serious medical need, Scott must show both that he suffered from an objectively serious medical need and that Benson actually knew of and deliberately disregarded that need.
4. The appellate court could not determine from the existing record whether Benson was entitled to qualified immunity because the district court applied the wrong constitutional standard and did not fully resolve or analyze the material factual disputes under the deliberate-indifference framework.

Questions Presented

1. Whether the Eighth Circuit had interlocutory appellate jurisdiction over the denial of summary judgment based on qualified immunity.
2. Whether the district court applied the correct constitutional standard to Scott's Fourteenth Amendment claim alleging constitutionally deficient medical care.
3. Whether the existing record permitted the appellate court to determine at that stage whether Benson was entitled to qualified immunity.

Disposition

vacated