Stephen E. Carswell v. Bay County, Lavelle Pitts, William Grigsby, Graham Belz, Thomas G. Merrill

Summary

The Eleventh Circuit affirmed judgments arising from the failure to provide adequate medical treatment to a county jail pretrial detainee under 42 U.S.C. § 1983 and related state-law negligence claims. The court held that a privately contracted jail physician acted under color of state law, that sufficient evidence supported findings of deliberate indifference, and that the jury verdict was not impermissibly inconsistent. The court also upheld the reduction of damages based on Bay County’s payment of the plaintiff’s medical expenses under Florida’s collateral-source rules.

Holdings

1. A private physician who contracts with the state or county to provide medical care to inmates acts under color of state law while performing those duties and may be liable under 42 U.S.C. § 1983.
2. The evidence was sufficient for the jury to find that Grigsby and Belz were deliberately indifferent to Carswell's serious medical needs.
3. The differing damages awarded on the constitutional and state negligence claims did not require disturbing the verdict because the evidence permitted a logical explanation for the different awards.
4. Florida's limitation on the collateral source rule barred Carswell from recovering from Grigsby medical expenses paid by Bay County, so those payments properly reduced the damage award.

Questions Presented

1. Whether a private physician contracting with a county jail to provide inmate medical services acts under color of state law and is subject to liability under 42 U.S.C. § 1983.
2. Whether sufficient evidence supported the jury's finding that Grigsby and Belz were deliberately indifferent to Carswell's serious medical needs.
3. Whether the jury's different compensatory-damage awards on the § 1983 and state negligence claims required vacatur of the judgment as inconsistent.
4. Whether Florida's collateral source rule permitted Carswell to recover medical expenses paid by Bay County from Grigsby notwithstanding Bay County's settlement and statutory right to recover those expenses.

Disposition

affirmed