Paul Scinto, Sr. v. Warden Stansberry

841 F.3d 219, 101 Fed. R. Serv. 1229, 2016 U.S. App. LEXIS 19936, 2016 WL 6543368
CourtCourt of Appeals for the Fourth Circuit
DecidedNovember 4, 2016
Docket15-1587
StatusPublished
Cited by702 cases

This text of 841 F.3d 219 (Paul Scinto, Sr. v. Warden Stansberry) 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
Paul Scinto, Sr. v. Warden Stansberry, 841 F.3d 219, 101 Fed. R. Serv. 1229, 2016 U.S. App. LEXIS 19936, 2016 WL 6543368 (4th Cir. 2016).

Opinion

Affirmed in part and reversed in part by published opinion. Judge WYNN wrote the opinion, in which Judge NIEMEYER and Judge MOTZ joined.

WYNN, Circuit Judge:

Plaintiff Paul Scinto, Sr. (“Plaintiff’), a former federal prisoner, sued several federal prison officials pursuant to Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388, 91 S.Ct. 1999, 29 L.Ed.2d 619 (1971), alleging a number of violations under the Fourth, Fifth, Eighth, and Fourteenth Amendments. Defendants are Dr. Derick Phillip (“Dr. Phillip”); Patricia Stansberry, former Federal Prison Camp Butner Warden (“Warden Stansberry”); and Susan McClintock, former Butner Camp Administrator (“Administrator McClintock”). Collectively, these Defendants successfully moved for summary judgment on all of Plaintiffs claims.

On appeal, Plaintiff limits his arguments to the district court’s dismissal of three claims that Defendants were deliberately indifferent to his medical needs, in violar tion of the Eighth Amendment. Plaintiff argues that, in dismissing these claims, the district court made credibility determinations and weighed the parties’ evidence, thus violating the summary judgment standard.

For the reasons that follow, we reverse the district court’s disposition of the two Eighth Amendment claims against Dr. Phillip and Administrator McClintock but affirm its resolution of the claim against Warden Stansberry.

*225 I.

The Eighth Amendment prohibits the infliction of “cruel and unusual punishments.” U.S. Const, amend. VIII. This prohibition “proscribes more than physically barbarous punishments.” Estelle v. Gamble, 429 U.S. 97, 102, 97 S.Ct. 285, 50 L.Ed.2d 251 (1976). It also encompasses “the treatment a prisoner receives in prison and the conditions under which he is confined.” Helling v. McKinney, 509 U.S. 25, 31, 113 S.Ct. 2475, 125 L.Ed.2d 22 (1993). In particular, the Eighth Amendment imposes a duty on prison officials to “provide humane conditions of confinement ... [and] ensure that inmates receive adequate food, clothing, shelter, and medical care.” Farmer v. Brennan, 511 U.S. 825, 832, 114 S.Ct. 1970, 128 L.Ed.2d 811 (1994). To that end, a prison official’s “deliberate indifference to serious medical needs of prisoners constitutes the unnecessary and wanton infliction' of pain proscribed by the Eighth Amendment.” Estelle, 429 U.S. at 104, 97 S.Ct. 285 (internal quotation marks and citation omitted). Prisoners alleging that they have been subjected to unconstitutional conditions of confinement must satisfy the Supreme Court’s two-pronged test set forth in Farmer v. Brennan, 511 U.S. 825, 114 S.Ct. 1970, 128 L.Ed.2d 811 (1994).

First, Farmer’s “objective” prong requires plaintiffs to demonstrate that “the deprivation alleged [was], objectively, ‘sufficiently serious.’ ” Farmer, 511 U.S. at 834, 114 S.Ct. 1970 (quoting Wilson v. Seiter, 501 U.S. 294, 298, 111 S.Ct. 2321, 115 L.Ed.2d 271 (1991)). To be “sufficiently serious,” the deprivation must be “extreme”—meaning that it poses “a serious or significant physical or emotional injury resulting from the challenged conditions,” or “a substantial risk of such serious harm resulting from ... exposure to the challenged conditions.” De’Lonta v. Angelone, 330 F.3d 630, 634 (4th Cir. 2003) (internal quotation marks and citation omitted). In medical needs cases, like the case at bar, the Farmer test requires plaintiffs to demonstrate officials’ deliberate indifference to a “serious” medical need that has either “been diagnosed by a physician as mandating treatment or ... is so obvious that even a lay person would easily recognize the necessity for a doctor’s attention.” Iko v. Shreve, 535 F.3d 225, 241 (4th Cir. 2008).

Second, under Farmer’s “subjective” prong, plaintiffs must show that prison officials acted with a “sufficiently culpable state of mind.” Farmer, 511 U.S. at 834, 114 S.Ct. 1970 (internal quotation marks omitted) (quoting Wilson, 501 U.S. at 297, 111 S.Ct. 2321). In conditions of confinement cases, the requisite state of mind is deliberate indifference. Id. To prove deliberate indifference, plaintiffs must show that “the official kn[ew] of and disregarded] an excessive risk to inmate health or safety.” Id. at 837, 114 S.Ct. 1970. Put differently, the plaintiff must show that the official was "aware of facts from which the inference could be drawn that a substantial risk of serious harm exist[ed], and .. dr[ew] th[at] inference.” Id. (emphasis added). Deliberate indifference is “more than mere negligence,” but “less than acts or omissions [done] for the very purpose of causing harm or with knowledge that harm will result.” Id. at 835, 114 S.Ct. 1970. It “lies somewhere between negligence and purpose or knowledge: namely, recklessness of the subjective type used in criminal law.” Brice v. Va. Beach Corr. Ctr., 58 F.3d 101, 105 (4th Cir. 1995) (citing Farmer, 511 U.S. at 835, 114 S.Ct. 1970). Under this standard, mere “[disagreements between an inmate and a physician over the inmate’s proper medical care” are not actionable absent exceptional circumstances. Wright v. Collins, 766 F.2d *226 841, 849 (4th Cir. 1985) (citing Gittlemacker v. Prasse, 428 F.2d 1, 6 (3d Cir. 1970)).

In deliberate indifference to medical needs cases, Farmer’s subjective prong requires proof of the official’s “actual subjective knowledge of both the inmate’s serious medical condition and the excessive risk posed by [the official’s] action or inaction.” Jackson v, Lightsey, 775 F.3d 170, 178 (4th Cir. 2014) (citing Farmer, 511 U.S. at 837-39, 114 S.Ct. 1970). A plaintiff can meet the subjective knowledge requirement through direct evidence of a prison official’s actual knowledge or circumstantial evidence tending to establish such knowledge, including evidence “that a prison official knew of a substantial risk from the very fact that the risk was obvious.” Makdessi v. Fields, 789 F.3d 126, 133 (4th Cir. 2015) (quoting Farmer, 511 U.S. at 842, 114 S.Ct. 1970).’

A plaintiff also makes out a prima facie case of deliberate indifference when he demonstrates “that a substantial risk of [serious harm] was longstanding, pervasive, well-documented, or expressly noted by prison officials in the past, and the circumstances suggest that the defendant-official ... had been exposed to information concerning the risk and thus must have known about it—” Parrish ex rel. Lee v. Cleveland, 372 F.3d 294, 303 (4th Cir. 2004) (first alteration in original) (internal quotation marks omitted) (quoting Farmer, 511 U.S. at 842, 114 S.Ct. 1970). Similarly, a prison official’s “[fjailure to respond to an inmate’s known medical needs raises an inference [of] deliberate indifference to those needs,” Miltier v. Beorn, 896 F.2d 848, 853 (4th Cir. 1990), overruled in part on other grounds by Farmer, 511 U.S. at 837, 114 S.Ct. 1970.

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Bluebook (online)
841 F.3d 219, 101 Fed. R. Serv. 1229, 2016 U.S. App. LEXIS 19936, 2016 WL 6543368, Counsel Stack Legal Research, https://law.counselstack.com/opinion/paul-scinto-sr-v-warden-stansberry-ca4-2016.