Patrick Cornwall v. Delaware County, et al.

Summary

The United States District Court for the Eastern District of Pennsylvania considers Defendants’ motion for summary judgment in Patrick Cornwall’s § 1983 action alleging constitutionally inadequate medical care while incarcerated at George W. Hill Correctional Facility. The court grants summary judgment for the individual defendants, finding insufficient evidence of deliberate indifference, but denies summary judgment for Delaware County and GEO Group on the Monell claim because disputed evidence could support a custom of delaying or improperly documenting access to seizure medication.

Holdings

1. Summary judgment was granted for Malloy, Wilson, Brown-Yarsiah, and Pierce because Cornwall presented no evidence from which a reasonable jury could find that any of them knowingly and consciously disregarded a substantial risk of serious harm. Malloy merely signed a medication-refusal form; Wilson treated Cornwall after his seizure; Brown-Yarsiah examined him and administered medication; and Pierce referred him for physical therapy after he reported shoulder pain.
2. The Monell claim was not deficient as a matter of law. Cornwall created a genuine factual dispute over whether Delaware County and GEO Group maintained a custom of delaying narcotic medication for non-medical reasons because staff lacked a key to a locked medication box, and of failing to document missed doses properly. A reasonable jury could find that this practice created a substantial risk of serious harm and reflected deliberate indifference by policymakers.
3. The court dismissed the shoulder-related theory because Cornwall did not report the shoulder injury until August 22, 2019, after which he received extensive medical attention, and his disagreement with the treatment provided did not establish deliberate indifference.

Questions Presented

1. Whether the individual medical defendants acted with deliberate indifference to Cornwall's serious medical needs in violation of the Eighth Amendment.
2. Whether the evidence could support municipal or corporate liability under Monell against Delaware County and GEO Group based on a policy or custom that delayed or denied medication for non-medical reasons and failed to document missed doses properly.
3. Whether Cornwall presented sufficient evidence of an unconstitutional policy or custom concerning treatment of his shoulder injury.

Disposition

other