Summary
This memorandum opinion from the United States District Court for the Eastern District of Pennsylvania grants summary judgment in favor of two prison physicians in a civil rights action brought by an incarcerated plaintiff. The court evaluates the plaintiff’s claims under the Eighth and Fourteenth Amendments regarding alleged non-consensual medical procedures and deliberate indifference to his healthcare needs. Applying Federal Rule of Civil Procedure 56, the court finds that the defendants’ actions were supported by professional medical judgment and documented informed consent, thereby lacking any underlying constitutional violation. Consequently, the court dismisses both the Eighth and Fourteenth Amendment claims.
Topics
Practice areas
Questions Presented
- Whether Defendants are liable under 42 U.S.C. §1983 for an Eighth Amendment claim of deliberate indifference to Plaintiff’s medical needs.
- Whether Defendants are liable under 42 U.S.C. §1983 for a Fourteenth Amendment substantive‑due‑process claim concerning the right to refuse medical treatment.
- Whether summary judgment is appropriate under Fed. R. Civ. P. 56.
Holdings
- Summary judgment is granted in favor of the defendants; the plaintiff failed to produce evidence of deliberate indifference or a material fact in dispute.
- Summary judgment is granted in favor of the defendants; the plaintiff offered no evidence that the defendants were personally involved in a denial of informed consent or acted with deliberate indifference.
- Summary judgment is appropriate because the moving parties have produced undisputed material facts and the non‑moving party has failed to produce evidence creating a genuine dispute.
Key quotations
“Summary judgment is appropriate “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a).”
“To state a claim under §1983, a plaintiff must allege the violation of a right secured by the Constitution and laws of the United States, and must show that the alleged deprivation was committed by a person acting under color of state law.”
Factual background
Kevin Quarles, an inmate at SCI‑Phoenix, complained of a right‑breast mass in February 2021. He underwent ultrasound, was referred by Dr. Goldberg to Dr. Bontempo, and ultimately underwent a right subcutaneous mastectomy and excision of a shoulder ganglion cyst on 23 July 2021. Quarles alleges he did not consent to the mastectomy and that the physicians acted with deliberate indifference, asserting Eighth Amendment and Fourteenth Amendment claims under 42 U.S.C. §1983.
Procedural history
Plaintiff filed the action on 24 April 2023 alleging §1983 violations of his Eighth and Fourteenth Amendment rights. The court dismissed official‑capacity claims, granted a motion to dismiss the Fourteenth Amendment equal‑protection claim, and later entertained summary‑judgment motions filed by Defendants Bontempo and Goldberg. After a bankruptcy stay was lifted, the court considered the parties’ filings and granted summary judgment to the defendants on all claims.