Jamael M. Hubbard v. Naphcare Medical Services

Summary

The United States District Court for the Middle District of Florida dismissed Jamael M. Hubbard’s pro se 42 U.S.C. § 1983 complaint against Naphcare Medical Services for failure to state a claim. The court held that Hubbard did not identify a Naphcare policy or custom causing the alleged constitutional violation and did not plead deliberate indifference to serious medical needs, as opposed to a disagreement over medical judgment. The dismissal was without prejudice, and Hubbard was granted leave to file an amended complaint by February 13, 2026.

Holdings

1. A private medical-services provider performing a governmental function is treated like a county for § 1983 purposes and is liable only when an official policy, custom, or practice causes the alleged constitutional violation; Hubbard failed to identify such a policy, custom, or practice.
2. The complaint failed to state a claim for deliberate indifference to serious medical needs because the allegations showed that Hubbard received medical treatment and amounted to a disagreement over diagnosis and treatment, rather than deliberate indifference.
3. The court granted Hubbard an opportunity to amend because this was the first dismissal identifying the pleading deficiencies and a more carefully drafted complaint might cure them.

Questions Presented

1. Whether Hubbard stated a § 1983 claim against Naphcare Medical Services by alleging inadequate medical care without identifying an official policy, custom, or practice attributable to Naphcare.
2. Whether Hubbard adequately pleaded deliberate indifference to serious medical needs based on receiving medical treatment that he believed was inadequate.
3. Whether Hubbard should be given leave to amend his deficient pro se complaint.

Disposition

dismissed