When Does a Claim of Medical Negligence Rise to the Level of a Constitutional Claim?

The United States Court of Appeals for the Tenth Circuit was faced with that question in Williams v. Corrections Corp., No. 17-7022 (10^th Cir. 2017). In this case, a federal prisoner, Mario Williams (“Williams”) filed an appeal to the grant of summary judgment in favor of Corrections Corporation, (“Corrections”) and other defendants. Williams had claimed inadequate medical care under the Eighth Amendment to the United States Constitution.

Williams claimed he was mistreated for injuries to his hands that were sustained during exercise at the Davis Correctional Facility (“DCF”). The United States District Court for the Eastern District of Oklahoma held that Williams had not established that the defendants acted with deliberate indifference, which is necessary for his claim to rise to the level of a Constitutional claim.

In 2013, when Williams sustained the injuries to his hands, he was examined more than once by nurses on staff at DCF. The second nurse realigned one of his fingers and thought that another finger was possibly fractured. Although a follow-up appointment was scheduled at that time, Williams filed an emergency grievance, and medical personnel took three x-rays of each hand that day. According to the physician’s report, the x-rays revealed that the hands were normal, with no fractures or dislocations. Williams filed more than one emergency grievance and requested an exam by a doctor. He was later transferred to a different prison. At that prison, an x-ray showed Williams had two broken fingers.

Williams appealed the granting of summary judgment in favor of Corrections. He says the district court disregarded evidence that he was never actually seen by a doctor (as opposed to a nurse) before his transfer, and evidence that later x-rays had proved that his hands were indeed fractured, which presumably could raise an inference that he had been misdiagnosed and mistreated. But the undisputed evidence shows that Plaintiff was repeatedly seen by medical personnel at DCF and the x-ray studies taken while he was there were negative. Thus, the evidence supports nothing more than claims of medical negligence—not enough for a constitutional claim. The Court of Appeals affirmed the lower court ruling.

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