Justia Medical Malpractice Opinion Summaries

Mario Mancini, an inmate at FCI Sandstone, sued the United States under the Federal Tort Claims Act (FTCA) for medical malpractice. Mancini alleged that the government caused him permanent injury by negligently delaying necessary medical care. He experienced neck and back pain from a prior workplace injury, which worsened in 2017. Despite reporting increasing pain and numbness, his MRI and subsequent surgery were delayed. Mancini claimed these delays resulted in permanent nerve damage, loss of strength, muscle atrophy, numbness, and pain.The United States District Court for the District of Minnesota dismissed Mancini's FTCA claim. The court found that Mancini's expert affidavit, provided by Dr. Gary Wyard, failed to meet the requirements of Minn. Stat. § 145.682. The affidavit did not adequately define the standard of care, explain how the government deviated from that standard, or establish a causal connection between the delays and Mancini's injuries. The court also excluded Dr. Wyard's testimony under Rule 702 and Daubert, citing factual errors and a lack of methodology in his affidavit.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that Dr. Wyard's affidavit did not satisfy the statutory requirements of Minn. Stat. § 145.682. The affidavit lacked specific details about the standard of care and failed to outline a chain of causation between the government's actions and Mancini's injuries. The court also upheld the exclusion of Dr. Wyard's testimony under Rule 702 and Daubert. The court concluded that the district court did not abuse its discretion in dismissing the case with prejudice, as Mancini did not correct the deficiencies in the affidavit within the provided safe-harbor period. View "Mancini v. United States" on Justia Law

Jeremy James Allen, while incarcerated at the Minnesota Correctional Facility in Faribault, filed a complaint against several officials alleging deliberate indifference and medical malpractice related to a hand injury from December 2017. He did not file any grievances with prison officials regarding his injury or medical treatment during his incarceration. Allen's complaint was initially filed in state court and later removed to federal court. After his release from custody, Allen amended his complaint, substituting Charles Brooks and Cheryl Piepho for previously unidentified defendants.The United States District Court for the District of Minnesota granted Allen's unopposed motion to amend his complaint after his release. The defendants moved to dismiss the complaint for lack of subject matter jurisdiction and failure to state a claim, but did not initially raise the issue of exhaustion of administrative remedies. The district court denied the motion to dismiss on qualified immunity grounds, finding that Allen plausibly alleged a violation of his Eighth Amendment right to adequate medical care.Brooks and Piepho later raised the failure to exhaust defense in a summary judgment motion, arguing that Allen's original complaint, filed while he was incarcerated, was subject to the Prison Litigation Reform Act (PLRA) exhaustion requirement. The district court denied their motion, ruling that the amended complaint, filed after Allen's release, was not subject to the PLRA's exhaustion requirement and did not relate back to the original complaint under Federal Rule of Civil Procedure 15(c).The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court held that Allen's amended complaint, filed after his release, was the operative complaint and not subject to the PLRA's exhaustion requirement. Additionally, the court found that the amended complaint did not relate back to the original complaint because naming John and Jane Doe defendants did not qualify as a "mistake" under Rule 15(c). View "Allen v. Brooks" on Justia Law

Sandra Jones, representing the estate of her deceased son Antonio Jones, filed a lawsuit under 42 U.S.C. § 1983 and Arkansas state law against Faulkner County, Arkansas, and jail officials Garry Stewart, Karen Grant, and Leanne Dixon. She claimed that the officials exhibited deliberate indifference to Antonio’s serious medical needs, violating his Fourteenth Amendment rights, and that Stewart committed medical malpractice. Jones also alleged that Faulkner County’s policies contributed to Antonio’s death.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. The court found that the jail officials were not deliberately indifferent to Antonio’s medical needs and that Jones could not establish a medical malpractice claim against Stewart due to the absence of a doctor-patient relationship. The court also dismissed the municipal liability claim against Faulkner County, concluding that no jail policy caused Antonio’s death.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the actions taken by Grant and Dixon did not constitute deliberate indifference. Grant responded to Antonio’s symptoms by placing him on a medical watch and took appropriate actions based on the information available to her at the time. Dixon, who was not a medical professional, followed her superior’s instructions and did not disregard any substantial risk of harm. The court also affirmed the dismissal of the municipal liability claim, as there was no constitutional violation by the county employees. Lastly, the court found no abuse of discretion in the district court’s exercise of supplemental jurisdiction over the state law claim against Stewart. View "Jones v. Faulkner County, Arkansas" on Justia Law

After a surgical procedure was performed on Elliot Kaplan as a result of a misdiagnosis, the Kaplans filed suit against Mayo for medical malpractice, breach of contract, lack of informed consent, and loss of consortium. The district court dismissed all claims against Dr. Nagorney, the surgeon who performed the medical procedure; the district court granted Mayo's motion for judgment as a matter of law on the breach-of-contract claim; and the jury returned a verdict for defendants on the malpractice claim. On appeal, the court upheld the jury verdict but vacated the judgment in favor of Mayo on the breach-of-contract claim, and held that the district court erred by requiring expert testimony to establish a contract breach and remanded the claim to trial. The district court subsequently entered judgment for Mayo. The court concluded that substantial evidence supports the district court's finding that Dr. Nagorney did not promise to do a biopsy of Elliot’s pancreas during the surgery and that no meeting of the minds occurred to form a contract. The court rejected plaintiffs' claim that this court, in Kaplan I, forbid defendants' use of expert testimony to establish a defense to the claim of a special contract in the performance of the operation. Because the district court committed no error, the court upheld the district court's factual findings. Accordingly, the court affirmed the judgment. View "Kaplan v. Mayo Clinic" on Justia Law

After plaintiff was released from a twenty-year period of commitment when a jury found him responsible by reason of insanity, he filed suit against various psychologists, psychiatrists, and other employees, alleging medical malpractice under Nebraska state law. Plaintiff also alleged violation of his constitutional rights to be free from unnecessary confinement and free from retaliation for seeking access to courts. The court concluded that the district court did not err by dismissing the medical malpractice claim where plaintiff failed to comply with the requirements set forth by Nebraska's State Tort Claims Act (STCA), Neb. Rev. Stat. 81-8, 209 et seq. Assuming that Nebraska waived its sovereign immunity, plaintiff still failed to bring the suit in the district court of the county in which the act or omission occurred pursuant to the STCA. In regard to the district court's dismissal of the unnecessary confinement claim, the court concluded that plaintiff only alleged defendants' actions were negligent or, at worst, grossly negligent. Therefore, defendants are entitled to qualified immunity where actions that are merely negligent or grossly negligent do no implicate the protections of the Due Process Clause. Finally, the court affirmed the district court's dismissal of plaintiff's retaliation claim where plaintiff failed to address the claim in his opening brief. View "Montin v. Moore" on Justia Law