Federal Court of Appeals Dismisses State Law Negligence Claim Against Prison Doctor Without Prejudice

When someone acts carelessly and causes harm to another, a negligence claim may lie under Massachusetts law. In some situations, the injured individual may have another claim as well. For example, the plaintiff in a recent case filed in federal court alleged that she had been the victim of negligence with regard to certain medical care (that she claimed she needed while a pre-trial detainee), while also asserting a civil rights claim under civil law. If you have questions of this nature, be sure to reach out to a Massachusetts personal injury attorney for answers.

Facts of the Case

The plaintiff in a recent federal case was a pre-trial detainee at a correctional institute. She filed suit against the defendants, a doctor and the healthcare group that employed him, seeking compensation for injuries she allegedly suffered due to the worsening of a medical condition that she had had for some time. According to the plaintiff, she had psoriasis and psoriatic arthritis and had been taking a certain medication prior to being lodged at the correctional institute (from which she was eventually released). She claimed that the defendants should have allowed her to continue taking that particular medication (rather than a combination of less expensive alternatives) and that their failure to do so amounted to a violation of her civil rights under federal law and also constituted negligence under Massachusetts state law.

The United States District Court for the District of Massachusetts granted summary judgment to the defendants on the plaintiff’s federal claim, holding that a reasonable jury could not find that there was deliberate indifference to the plaintiff’s serious medical needs by the defendants. The court also dismissed (without prejudice) the plaintiff’s negligence claim after ruling that she did not have a viable claim under federal law. The plaintiff appealed.

The Court’s Decision on Appeal

The United States Court of Appeals for the First Circuit affirmed. The plaintiff argued on appeal that the defendants knew enough about her medical history to “make it obvious” that the course of treatment prescribed for her (which included various, less expensive medications than the one that the plaintiff had been taking before becoming a pre-trial detainee) amounted to a refusal to provide essential care, thus triggering a claim for violation of her civil rights under the 8th Amendment and 42 U.S.C. § 1983. The appellate court disagreed, however, pointing out that the defendant doctor’s only involvement was to review non-formulary medication requests. Because the plaintiff could not prove that the defendants acted with deliberate intent to harm her or with wanton disregard for her health, the court of appeals dismissed her federal claim.

The appellate court did not reach the issue of whether the plaintiff had stated a state law claim for negligence. However, because her negligence claim was dismissed without prejudice after the federal claim was denied, the plaintiff may be able to pursue her negligence claim in state court.

Speak to a Massachusetts Injury Lawyer

There are many ways in which one person or business’s neglect can cause serious harm or even death to another. If you or a loved one has been hurt because another party breached a duty of care that was owed to you or loved one, you may have a claim for compensation. At the Law Offices of John C. Manoog, III, we handle many types of negligence and personal injury cases. To schedule a free consultation, call us at 888-262-6664, and we will be happy to set up an appointment in our Hyannis or Plymouth offices at your convenience. Nos falamos Portugues.

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