Michael Cox v. Bernadette Mason, et al.

Summary

The United States District Court for the Middle District of Pennsylvania considered defendant Jenna Williams’s unopposed motion for summary judgment in Michael Cox’s 42 U.S.C. § 1983 action alleging deliberate indifference to serious medical needs. The court reviewed Cox’s medical records concerning worsening back and neurological symptoms, his February 2021 emergency hospitalization and cervical surgery, and subsequent treatment. The court granted the motion for summary judgment.

Holdings

1. A nonmoving party does not lose a summary-judgment motion by default merely by failing to respond; the court must still determine whether the undisputed record establishes that the movant is entitled to judgment as a matter of law.
2. Williams was entitled to summary judgment because the undisputed record did not permit a reasonable factfinder to conclude that she acted with deliberate indifference to Cox's serious medical needs.
3. A prisoner's disagreement with the course or adequacy of medical treatment, without more, does not establish deliberate indifference under the Eighth Amendment.
4. Williams's alleged statement that Cox was faking or lying about his symptoms, viewed in the light most favorable to Cox, did not itself constitute an Eighth Amendment violation.

Questions Presented

1. Whether the court could grant summary judgment despite Cox's failure to respond to the motion and statement of material facts.
2. Whether the undisputed record established that PA Williams was deliberately indifferent to Cox's serious medical needs in violation of the Eighth Amendment and 42 U.S.C. § 1983.
3. Whether Cox's disagreement with the course of medical treatment or Williams's alleged statement that he was faking symptoms established a constitutional violation.

Disposition

other