Ruben C. Holton v. United States

Summary

The United States District Court for the Middle District of Pennsylvania adopted a magistrate judge’s report and recommendation and granted the United States’ motion for summary judgment. The court concluded that Holton failed to provide expert evidence supporting his professional negligence claim and failed to provide evidence sufficient to support his ordinary negligence claims concerning lingering COVID-19 symptoms allegedly arising from his incarceration at FCI Schuylkill.

Holdings

1. The plaintiff's failure to file timely objections forfeited de novo review, and the court reviewed the uncontested portions of the report and recommendation for clear error while giving them reasoned consideration.
2. Summary judgment was proper on the plaintiff's professional-negligence or medical-malpractice claim because he failed to provide supporting expert testimony or other expert evidence necessary to create a genuine issue of material fact.
3. Summary judgment was proper on the plaintiff's ordinary-negligence claims because he produced no evidence showing refused or delayed medical treatment, flawed treatment, or another government act supporting liability.

Questions Presented

1. Whether the report and recommendation recommending summary judgment for the United States should be adopted where the plaintiff filed no timely objections.
2. Whether the plaintiff could proceed on a professional-negligence claim without supporting expert testimony.
3. Whether the plaintiff produced sufficient evidence to create a genuine issue of material fact on his ordinary-negligence claims.

Disposition

other