Summary
The Fourth Circuit held that the evidence did not support a deliberate-indifference claim against the prison medical personnel or correctional officers who attended to the inmate before 8:30 a.m. on May 10, 1981. It reversed summary judgment for the guards on duty after that time, concluding that prisoner affidavits created material factual disputes about whether the guards knowingly delayed obtaining medical assistance despite the inmate’s deteriorating condition. The case was remanded for trial as to those guards.
Topics
Practice areas
Questions Presented
- Whether the evidence raised a genuine issue of material fact that prison medical personnel were deliberately indifferent to Land's serious medical needs in violation of 42 U.S.C. § 1983.
- Whether the evidence raised a genuine issue of material fact that correctional officers acted with deliberate indifference by failing to obtain medical assistance after Land's condition substantially worsened.
- Whether summary judgment was proper when resolution of the guards' knowledge and conduct required credibility determinations concerning inmate affidavits.
Holdings
- Summary judgment was proper for the medical personnel and correctional officers on duty from May 6, 1981, through Land's 8:30 a.m. infirmary visit on May 10 because the record showed repeated medical attention and did not establish deliberate indifference.
- The evidence created a genuine issue of material fact as to whether the guards on duty after 8:30 a.m. on May 10 and before Land's death deliberately ignored his obvious, life-threatening medical condition by refusing to obtain medical assistance.
- The district court could not discredit the inmate affidavits or resolve their credibility at summary judgment; those credibility issues had to be left to the trier of fact.
Key quotations
“Medical malpractice does not become a constitutional violation merely because the victim is a prisoner.” (180)
“If an eleven hour delay in caring for a broken arm is abnormal, a ten hour (or more) delay in attending to a deadly illness is likewise abnormal.” (182)
“Only the trier of fact can assess the truthfulness of an affidavit.” (182)
“Such facts provide a reasonable basis for finding a deliberate indifference to Land’s medical needs.” (183)
Factual background
Gary McArthur Land, who was incarcerated at the Maximum Security Center in Columbia, South Carolina, developed neck and chest pain after eating a steak. Although he was examined and treated by prison medical personnel on several occasions, a pathological report indicated that a steak bone had pierced his esophagus and caused an infection, and he died in his cell. Evidence from inmate affidavits indicated that, after Land's condition worsened following an 8:30 a.m. infirmary visit on Sunday, guards knew of his serious condition, refused to obtain further medical assistance until Monday, and threatened inmates who continued seeking help.
Procedural history
The district court concluded that no genuine issue of fact existed regarding violations of §§ 1982 or 1983 and declined to exercise pendent jurisdiction over the malpractice claim. The Fourth Circuit affirmed summary judgment for the medical personnel and correctional officers on duty through the decedent's 8:30 a.m. infirmary visit on May 10, 1981, but reversed as to the guards allegedly responsible during the period thereafter and remanded for trial.
Remand instructions
Remand the portion of the case concerning the guards on duty after 8:30 a.m. on Sunday, May 10, until Land's death on Monday morning for trial. The judgment remains affirmed as to the medical personnel and correctional officers on duty through the 8:30 a.m. infirmary visit.