Lauren Spurlock v. Wexford Health Sources, Inc.

CourtCourt of Appeals for the Fourth Circuit
DecidedMay 4, 2026
Docket25-2038
StatusPublished

This text of Lauren Spurlock v. Wexford Health Sources, Inc. (Lauren Spurlock v. Wexford Health Sources, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lauren Spurlock v. Wexford Health Sources, Inc., (4th Cir. 2026).

Opinion

USCA4 Appeal: 25-2038 Doc: 48 Filed: 05/04/2026 Pg: 1 of 31

PUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-2038

LAUREN SPURLOCK; HEATHER SMITH; and SHAWN ZMUDZINSKI, individually and on behalf of all others similarly situated,

Plaintiffs - Appellees,

v.

WEXFORD HEALTH SOURCES, INC.,

Defendant - Appellant.

Appeal from the United States District Court for the Southern District of West Virginia, at Huntington. Robert C. Chambers, District Judge. (3:23-cv-00476)

Argued: December 9, 2025 Decided: May 4, 2026

Before BENJAMIN and BERNER, Circuit Judges, and John A. GIBNEY, Jr., Senior United States District Judge for the Eastern District of Virginia, sitting by designation.

Affirmed in part and remanded in part by published opinion. Judge Berner wrote the opinion, in which Judge Benjamin and Judge Gibney joined.

ARGUED: Michael James Bentley, BRADLEY ARANT BOULT CUMMINGS LLP, Jackson, Mississippi, for Appellant. William J. Forbes, FORBES LAW OFFICES, PLLC, Charleston, West Virginia, for Appellees. ON BRIEF: Jordan K. Herrick, Justin C. Taylor, Harrison M. Cyrus, BAILEY & WYANT, PLLC, Charleston, West Virginia; Erin Saltaformaggio, P. Garner Vance, BRADLEY ARANT BOULT CUMMINGS LLP, Jackson, Mississippi, for Appellant. Hassan A. Zavareei, Glenn E. Chappell, Gemma Seidita, TYCKO & ZAVAREEI LLP, Washington, D.C.; F. Paul Bland, Jr., Julie S. USCA4 Appeal: 25-2038 Doc: 48 Filed: 05/04/2026 Pg: 2 of 31

Selesnick, Washington, D.C., Natalie Lesser, Philadelphia, PA, BERGER MONTAGUE PC; Jennifer N. Taylor, FORBES LAW OFFICES, PLLC, Charleston, West Virginia; L. Danté diTrapano, David Carriger, CALWELL LUCE DITRAPANO PLLC, Charleston, West Virginia, for Appellees.

2 USCA4 Appeal: 25-2038 Doc: 48 Filed: 05/04/2026 Pg: 3 of 31

BERNER, Circuit Judge:

Lauren Spurlock, Heather Smith, and Shawn Zmudzinski suffer from opioid use

disorder and allege that they were denied access to medical screening and treatment for

opioid dependence while incarcerated. They seek to represent two classes of similarly

situated individuals in this class action lawsuit against Wexford Health Sources, Inc.

Wexford, a medical services corporation, contracts with prisons and jails throughout the

United States to provide comprehensive medical care services to incarcerated individuals.

Spurlock, Smith, and Zmudzinski allege that Wexford violated their rights under the

Eighth and Fourteenth Amendments by failing to screen for and treat opioid dependence.

They assert that Wexford maintains a policy exempting medical care for opioid dependence

from the otherwise comprehensive medical care it provides to incarcerated individuals. As

a result, individuals who suffer from opioid dependence are forced to undergo painful

opioid withdrawal.

The district court certified two classes of plaintiffs. The first class seeks a court

order requiring Wexford to provide screening and treatment to individuals with opioid use

disorder who are incarcerated in institutions where Wexford provides comprehensive

medical care. The second class seeks damages for Wexford’s past failure to provide this

screening and treatment. For the reasons set forth below, we remand for the district court

to consider in the first instance whether Spurlock, Smith, and Zmudzinski have standing to

represent the class seeking injunctive relief. We affirm the district court’s order certifying

the class seeking damages.

3 USCA4 Appeal: 25-2038 Doc: 48 Filed: 05/04/2026 Pg: 4 of 31

I.

The tragedy of opioid dependence has led to “an extraordinary public health crisis

that started at least two decades ago and has accelerated over the past decade.” City of

Huntington v. AmerisourceBergen Drug Corp., 96 F.4th 642, 647 (4th Cir. 2024) (internal

citations omitted). Our nation’s jails and prisons have been at the forefront of grappling

with this crisis. See Criminal Justice Drug Facts, Nat’l Inst. on Drug Abuse (June 2020),

https://nida.nih.gov/publications/drugfacts/criminal-justice [https://perma.cc/YN46-

7ASM]. Studies suggest that sixty-five percent or more of incarcerated individuals suffer

from moderate to severe substance use disorder, including opioid use disorder (OUD).

OUD is a progressive brain disease characterized by uncontrollable cravings for and/or

dependence upon opioids. This case raises constitutional challenges to the medical

treatment provided by Wexford to individuals suffering from OUD in carceral settings. We

will first detail the generally accepted medical protocols for treatment of OUD before

reciting the facts of this case.

A. Medical treatment for opioid use disorder

In 2002, the federal Food and Drug Administration (FDA) first approved the current

medically accepted treatment protocol for OUD, known as medications for opioid use

disorder or MOUD. 1 Under this protocol, patients are prescribed small doses of opioids in

a controlled manner, thereby allowing them to manage their dependence and relieve

Earlier forms of medication-assisted treatment for OUD were first approved by the 1

FDA in the 1960s. 4 USCA4 Appeal: 25-2038 Doc: 48 Filed: 05/04/2026 Pg: 5 of 31

withdrawal symptoms. Like insulin for a diabetic, these medications can be used daily

throughout an individual’s lifetime to treat OUD. MOUD has proved to be highly effective,

drastically reducing the risk of relapse and death from opioid overdose.

The broadly accepted evidence-based medical standard of care for OUD calls for

screening for and, where medically appropriate, prescribing MOUD. The World Health

Organization, National Institute on Drug Abuse, Substance Abuse and Mental Health

Services Administration, National Sheriffs’ Association, Centers for Disease Control and

Prevention, American Medical Association, and the American Academy of Pediatrics all

recommend that medical providers follow this protocol. See, e.g., Am. Soc’y of Addiction

Med., The ASAM National Practice Guideline for the Treatment of Opioid Use Disorder:

2020 Focused Update 11 (2020), https://sitefinitystorage.blob.core.windows.net/sitefinity-

production-blobs/docs/default-source/guidelines/npg-jam-

supplement.pdf?sfvrsn=a00a52c2_2 [https://perma.cc/7EVU-RQ6Z].

Notably, the process of withdrawal from opioids, also known as detoxification, is

not even considered to be a medical treatment for OUD. Symptoms of withdrawal can

cause significant suffering and even lead to death. Withdrawal carries with it both short-

term and long-term consequences. In the short-term, individuals may experience

“uncontrolled pain, psychological distress, suicidal ideation, and suicide attempts.”

Investigation of the Cumberland County Jail (Bridgeton, New Jersey), U.S. Dep’t of Just.,

C.R. Div. (Jan. 14, 2021), https://www.justice.gov/usao-nj/press-release/file/1354736/dl

[https://perma.cc/6BS4-4BYC]. In the long-term, individuals may face an increased risk of

5 USCA4 Appeal: 25-2038 Doc: 48 Filed: 05/04/2026 Pg: 6 of 31

relapse, overdose, and death. Id. For those already prescribed MOUD, sudden cessation of

the medication can cause withdrawal symptoms similar to opioid withdrawal itself.

B. Factual background

Wexford is a private medical corporation that contracts with nearly one hundred

jails and prisons around the country to provide comprehensive medical care services to

detained and incarcerated individuals. 2 Wexford’s Corporate Addiction Program Manager

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