Strong v. United States

CourtDistrict Court, E.D. Arkansas
DecidedMarch 17, 2025
Docket2:22-cv-00191
StatusUnknown

This text of Strong v. United States (Strong v. United States) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Strong v. United States, (E.D. Ark. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS DELTA DIVISION

ANTONIO STRONG PLAINTIFF Reg. #46018-044

v. Case No. 2:22-cv-00191-LPR-JJV

USA DEFENDANT ORDER The Court has received and reviewed Judge Volpe’s Partial Recommended Disposition (PRD), recommending that the United States’ Motion for Summary Judgment be denied.1 No objections have been filed and the time to do so has expired. Nonetheless, the Court has conducted a de novo review of the PRD and has carefully considered the entire record. Respectfully, the Court parts ways with the PRD. For the reasons discussed below, the Court GRANTS the United States’ Motion for Summary Judgment.2 Much of the PRD is correct. First, the PRD is correct that, because Plaintiff did not respond to the summary judgment papers, all of the facts in the United States’ Statement of Material Facts are deemed admitted.3 Second, the PRD is (as a general matter) correct—though not entirely complete—in the basic timeline of events and background information it provides.4 Third, the PRD is correct that, by virtue of the interaction between the FTCA and the Arkansas Medical Malpractice Act, a plaintiff must have expert testimony establishing the standard of care, a breach of that standard, and proximate causation unless the issue is within the jury’s comprehension as a

1 Partial Recommended Disposition (Doc. 53). 2 Mot. for Summ. J. (Doc. 44). 3 See Partial Recommended Disposition (Doc. 53) at 2; Local Rule 56.1(c). 4 See Partial Recommended Disposition (Doc. 53) at 2–6. matter of common knowledge.5 Fourth, the PRD is correct that Plaintiff has not provided any evidence from which a reasonable jury could conclude that the 12-day delay between the initial hand injury and Plaintiff’s first visit to the hospital was the proximate cause of any further injury to Plaintiff’s hand.6

Given the significant areas of agreement just discussed, this Court is not going to recreate the wheel with an entirely new opinion. Instead, the Court simply explains its main disagreements with the PRD and why those disagreements require granting summary judgment to the United States. 1. The first area of disagreement concerns Plaintiff’s lack of an expert. The PRD appears to conclude that Plaintiff can survive summary judgment in this case without an expert.7 The Court disagrees. At the outset, it is only fair to acknowledge that Plaintiff is a pro se litigant and prisoner. But, just as importantly, the Court also notes that Plaintiff has never asked for appointed counsel or a government-funded expert. This case was originally filed in October of 2022.8 Discovery

initially opened in February of 2023.9 And discovery did not close until May 17, 2024.10 Certainly, if Plaintiff wanted appointed counsel or a government-funded expert, he had plenty of time to ask for those things. If Plaintiff had sought counsel or an expert—and had been rebuffed by the Court—the Court might feel differently about the implications of his failure to proffer expert

5 See id. at 6; 28 U.S.C. § 1346(b)(1); Ark. Code. Ann. § 16-114-206(a). 6 See Partial Recommended Disposition (Doc. 53) at 6–7. 7 Id. at 8. 8 See Compl. (Doc. 2). 9 See Feb. 27, 2023 Initial Scheduling Order (Doc. 14). 10 See Oct. 3, 2023 Initial Scheduling Order (Doc. 41); Mot. to Extend Time (Doc. 42); Apr. 1, 2024 Order (Doc. 43). testimony for summary judgment purposes. But that is not where we are. Plaintiff’s lack of an expert is his own doing. That is a real problem for Plaintiff. In the Court’s view, pursuant to the dictates of the Arkansas Medical Malpractice Act, Plaintiff needs expert testimony to show that the delay in

getting him to an orthopedic follow-up appointment (after his initial hospital visit) was the proximate cause of some damage to his hand that was in excess of the damage caused by the original injury.11 This is because whether the delay contributed to additional damage is not a matter within the common knowledge of lay jurors.12 The PRD seems to acknowledge as much. It describes as “persuasive” the United States’ argument “that Plaintiff has not [shown] by [means of] a qualified medical expert how any alleged delay in treatment caused him injury from which he did not already suffer due [to] the [initial injury] itself . . . .”13 And it explicitly “agree[s] with” the United States “that . . . whether any injury was proximately caused by a breach of” “the standard of care for a displaced metacarpal bone with mild volar angulation” is a matter “beyond the ‘common knowledge’ of a fact finder in

the absence of expert testimony.”14 If all that is true—and the Court thinks it is—then the ineluctable conclusion must be that Plaintiff’s lack of an expert is fatal to his case.15

11 See Ark. Code Ann. § 16-114-206(a)(3). 12 See Spring Creek Living Ctr. v. Sarrett, 319 Ark 259, 262, S.W.2d 598, 600 (1995) (“[C]laims based on allegations of a failure to provide needed medical care and attention . . . come within the ambit of the Medical Malpractice Act and are dependent upon expert testimony.”). 13 Partial Recommended Disposition (Doc. 53) at 8. 14 Id. 15 At one point, the PRD seems to suggest that, if summary judgment is denied, Plaintiff (with court-appointed counsel) should either privately retain an expert or seek a government-funded expert from the Court. See Partial Recommended Disposition (Doc. 53) at 9. The PRD’s suggestion is further evidence that the PRD believes expert testimony is necessary in this case. If expert testimony is necessary to prove Plaintiff’s case at trial and Plaintiff does not have that testimony at this point, summary judgment for Defendant is the lawful resolution of the case. That might be harsh in the circumstances, but sometimes the law is harsh. The PRD does go on to—somewhat cryptically—say that record evidence “create[s] a genuine issue of material fact even without expert testimony.”16 But the PRD never exactly says what the genuine issue of material fact is. In any event, and more to the point, the abstract existence of a genuine issue of material fact is not enough to survive summary judgment in a case like this

one, which is governed by the specific requirements of the Arkansas Medical Malpractice Act. Because Plaintiff needs expert testimony on proximate causation to prevail at trial, he must have provided expert testimony on the point at the summary judgment phase. And because he did not do so, the United States is entitled to judgment as a matter of law regardless of the strength or weakness of its medical expert.17 2. The second area of disagreement concerns the PRD’s treatment of certain facts provided by the United States’ medical expert, Dr. Jeff Johnson. The PRD takes issue with some of the testimony provided by Dr. Johnson. For example, when discussing Plaintiff’s January 31, 2022 visit to an orthopedist, the PRD states: [Dr. Johnson] . . . says in his declaration that “there was no obvious rotational deformity, crossover, or scissoring, and . . . [Plaintiff’s] long term outcome looked good. Moreover, there was no change in his alignment to suggest a rotational deformity which, if present, might hinder his function.” But I could not find any support for those assertions in the Clinical Notes or Radiological Report. And Dr. Johnson’s declaration does not explain how he reached that conclusion.18

The PRD’s questioning of the Johnson testimony does not grapple with the implications of Plaintiff’s failure to respond to the summary judgment papers. In the United States’ Statement of

16 Partial Recommended Disposition (Doc. 53) at 8. 17 See Johnson v. Schafer, 2018 Ark. App.

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Related

Spring Creek Living Center v. Sarrett
890 S.W.2d 598 (Supreme Court of Arkansas, 1995)
Johnson v. Schafer
2018 Ark. App. 630 (Court of Appeals of Arkansas, 2018)

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Bluebook (online)
Strong v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/strong-v-united-states-ared-2025.