Lewellen v. Schneck Med. Ctr. — Aug. 2007 (Full Text)
NA 05-0083-C T/H Lewellen v Schneck Medical Ctr
Judge John D. Tinder
Signed on 08/16/07
NOT INTENDED FOR PUBLICATION IN PRINT
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF INDIANA
NEW ALBANY DIVISION
KEVIN LEWELLEN, )
JANET LEWELLEN, )
)
Plaintiffs, )
vs. ) NO. 4:05-cv-00083-JDT-WGH
)
SCHNECK MEDICAL CENTER, )
A. DAVIS RN, )
JOHN M. REISERT MD, )
SHARON DUFFIELD RN, )
JOHN F. ALEXANDER MD, )
)
Defendants. )
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF INDIANA
NEW ALBANY DIVISION
KEVIN LEWELLEN and JANET
LEWELLEN,
Plaintiffs,
vs.
SCHNECK MEDICAL CENTER a/k/a
SCHNECK MEMORIAL HOSPITAL, A.
DAVIS, R.N., JOHN M. REISERT, M.D.,
JOHN F. ALEXANDER, M.D., and
SHARON DUFFIELD, R.N.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
4:05-cv-0083-JDT-WGH
ENTRY ON DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT (Doc. Nos. 45,
54 & 88)1
While driving drunk through Jackson County, Indiana, Plaintiff Kevin Lewellen ran
off the interstate and suffered a burst fracture in his lower back. He was taken to
Defendant Schneck Memorial Hospital (“Schneck”) but was discharged without the burst
fracture being diagnosed. He was then taken immediately to jail for operating a vehicle
while intoxicated. Over the course of his stay in jail, his fracture caused permanent
damage.
This matter comes before the court on Defendants’ motions for summary
judgment. (Doc. Nos. 45, 54 & 88.) Plaintiff sues Defendant health care providers
1 This Entry is a matter of public record and will be made available on the court’s web
site. However, the discussion contained herein is not sufficiently novel to justify commercial
publication.
under 42 U.S.C. § 1983 and the Emergency Medical Treatment and Labor Act, 42
U.S.C. § 1395dd (“EMTALA”).2 Plaintiff argues that two doctors and two nurses at
Schneck violated his Fourteenth Amendment rights to adequate medical care as a
pretrial detainee. He also argues that defendant hospital violated EMTALA’s screening
and stabilization requirements. Defendants Dr. Reisert and Dr. Alexander filed separate
motions for summary judgment, followed by a motion for summary judgment from
Schneck with Nurses Davis and Duffield. All three motions are ripe and the court rules
as follows:
2 Mr. Lewellen’s wife, Janet, is also named as a Plaintiff in this case. The Lewellens’
complaint contains a cause of action for Janet Lewellen’s loss of consortium through EMTALA.
This claim was not addressed in the parties’ briefs and so survives summary judgment.
However, for the sake of clarity, and because only Mr. Lewellen’s claims are discussed in the
briefs on this motion, throughout this Entry the court will refer to Plaintiff in the singular.
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Table of Contents
I.
Summary Judgment Standard . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -1-
II.
Facts for Summary Judgment
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -1-
III.
Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -9-
A.
42 U.S.C. § 1983 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -10-
1.
2.
3.
State Action and Under Color of State Law
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -10-
Custody . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -21-
Deliberate Indifference . . . . . . . . . . . . . . . . . . . . -23-
B.
EMTALA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -33-
1.
2.
Substance of the EMTALA Claim . . . . . . . . . . . . -34-
Medical Malpractice Act
. . . . . . . . . . . . . . . . . . . -37-
IV.
Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -43-
-iii-
I.
Summary Judgment Standard
Summary judgment is appropriate where the pleadings, depositions, answers to
interrogatories, affidavits and other materials demonstrate that there exists “no genuine
issue as to any material fact and that the moving party is entitled to a judgment as a
matter of law.” Fed. R. Civ. P. 56(c). When deciding a motion for summary judgment,
the court considers those facts that are undisputed and views additional evidence, and
all reasonable inferences drawn therefrom, in the light reasonably most favorable to the
nonmoving party. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986);
Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986); Baron v. City of Highland Park, 195
F.3d 333, 337-38 (7th Cir. 1999). In order to survive a motion for summary judgment, a
party must “set forth facts showing that there is a genuine issue for trial.” Fed. R. Civ.
P. 56(e).
II.
Facts for Summary Judgment
Plaintiff Kevin Lewellen is a registered nurse anesthetist in Paris, Tennessee,
who made a terrible mistake on June 8, 2003. After a weekend visit with his cousin in
Greenwood, Indiana, Lewellen began the roughly 350 mile journey home with a drink of
scotch. He stopped between Greenwood and Interstate 65 to open his trunk and pour
another glass of scotch and drink it; then he continued on his way. Whether these were
his only drinks that morning or not, three hours later his blood alcohol content would be
nearly four times the legal limit and he would be heading to the hospital, afterwards to
jail.
-1-
Lewellen’s bad judgment caught up with him somewhere in Jackson County,
Indiana, near Seymour. While traveling on Interstate 65, his vehicle left the road, rolled
once, and ended up in a ditch fifty to one hundred yards from the highway.3 The
accident involved only Lewellen’s car, which was badly damaged. Lewellen was also
injured in the accident.
When Troopers Roger Drew and Rick Hudson of the Indiana State Police arrived
at the accident site, paramedics were already there placing Lewellen on a stretcher and
loading him into an ambulance. Lewellen was, according to Drew, clearly intoxicated.
The Troopers had the EMTs draw blood from Lewellen to test his blood alcohol level.4
According to the probable cause determination filed the next day in Jackson County
Superior Court, the time of arrest was 2:22 pm. But because Lewellen had been in an
accident and was complaining of lower back pain, the EMTs transported him to Schneck
Memorial Hospital (“Schneck”),5 a county-owned hospital. Troopers Drew and Hudson
completed some work at the accident site and then proceeded to Schneck to await
Lewellen’s release.
3 Exactly what circumstances led to the crash—other than Lewellen’s intoxication—are
cloudy; Lewellen remembers little. The police report indicates that Lewellen was traveling
northbound (i.e., in the opposite direction of his destination). Lewellen believes he was traveling
southbound. Lewellen claimed at the time of the accident that he had fallen asleep at the
wheel, but now admits that he missed an exit ramp and may have misled the police at the scene
out of fear. At any rate, these facts are not relevant to the outcome of this motion.
4 The record does not indicate whether Lewellen consented to the blood being taken or
not.
5 The hospital is now know as Schneck Medical Center.
-2-
Piecing together what transpired at the hospital is complicated by the fact that
Lewellen’s recollection is understandably hazy and all of the personnel at Schneck deny
any memory of the incident. But a basic narrative can be cobbled together from the
hospital records, from Lewellen’s patchy recollections, and from the State Troopers,
who in contrast to the health care providers, do remember the events of June 8, 2003.
According to hospital records, Defendant Amanda Davis, a nurse in the
Emergency Department, admitted Lewellen to the hospital shortly after 3:00 p.m. She
did an initial assessment and noted on Lewellen’s chart that he had been in a motor
vehicle accident. After this initial assessment, Defendant John M. Reisert, a doctor on
duty, examined Lewellen. Reisert noted that Lewellen was complaining of lower back
pain and his lumbar spine was tender. Reisert ordered x-rays of Lewellen’s lumbar and
cervical spine to determine whether Lewellen had fractured his back in the accident.
Lewellen was then taken to the x-ray room. Construing the facts most favorably
to Lewellen,6 several x-rays were taken of Lewellen while he was flat on his back with
no trouble. However, when the technicians tried to turn Lewellen on his side to get a
different view, Lewellen remembers being in significant pain. Somewhere in the
process Dr. Reisert modified his order to eliminate several of these views requiring
6 The accounts of what transpired in the x-ray room vary. Although no one but Lewellen
remembers the events, the hospital records blame the poor quality of the x-rays on Lewellen’s
abusive and uncooperative behavior. Lewellen contends that to the extent he was
uncooperative it was due to the tremendous amount of pain he was in as the x-ray technicians
attempted to turn him. Trooper Drew backs Lewellen’s version by stating that Lewellen was
nothing but cooperative when he observed him. In any case, the facts must be construed in
Lewellen’s favor.
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Lewellen to be turned on his side. One technician noted in Lewellen’s records that he
was “uncooperative [and] made threats to staff.” (Pls.’ Ex. 10, at 010.) The final x-ray
was a lateral view (essentially a side view) of his lumbar spine, requiring Lewellen to be
rolled on his side ninety degrees.
At 3:51 p.m., the lab report on Lewellen’s blood alcohol test revealed that he had
a blood alcohol level of .297. Before the last of Lewellen’s x-rays had even printed, at
4:07 p.m., Davis informed Lewellen that Reisert was discharging him. This was less
than one hour after Lewellen had been admitted to the hospital. Lewellen refused to
sign the consent to discharge, pleaded with Davis that he was in tremendous pain and
begged to talk to the doctor. Nurse Davis told Trooper Drew, who was at the hospital
waiting for Lewellen with Trooper Hudson, that Lewellen was not cooperating in the
discharge and asked if Drew would sign the discharge. Drew refused.
Drew then went to Lewellen and explained what the investigation had revealed
and that Lewellen would have to go to the county jail. Drew claims that Lewellen was
not combative or uncooperative, but Lewellen was insistent that he was in great pain
and that the hospital had not examined him sufficiently. Drew asked Nurse Davis about
Lewellen’s pain and asked if the hospital was really done examining him. Nurse Davis
responded that Lewellen was fine, he was just drunk.
However, Lewellen was in too much pain to stand or walk. Drew got Trooper
Hudson to help him put Lewellen in a wheelchair that nurse Davis was holding steady.
Lewellen could not even sit properly in the wheelchair. According to Drew, Lewellen
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assured Drew that “I’m not upset with you, I’m in pain. Something is wrong and I can’t
stand up.” (Drew Aff. ¶ 8.) Throughout this process, Lewellen continued to plead with
the officers and Nurse Davis that he was in pain and that something was wrong. Drew
explained to Lewellen that once the hospital had discharged him he had no choice but
to transport Lewellen to jail.
At 4:10 p.m., three minutes after Nurse Davis attempted to get Lewellen to sign
his discharge papers, Lewellen was discharged from the hospital. At exactly the same
time, according to hospital records, the last of Lewellen’s x-rays came off the printer.
Lewellen contends that Dr. Reisert did not even bother to look at these x-rays before
deciding to discharge him. And given the fact that some of the x-rays were not printed
until after Lewellen was informed he was being discharged, this fact can be construed in
his favor. At some point, whether before or after Lewellen was discharged, Reisert
wrote on the ER chart that the x-rays revealed no fracture and that Lewellen’s lack of
cooperation caused the films to be of poor quality.
Because of the amount of pain that Lewellen was in, Troopers Drew and Hudson
varied from normal practice and handcuffed Lewellen in the front rather than the back
as they transported him to jail. Officer McPherson was working in the Jackson County
Jail that afternoon and observed Lewellen screaming out in pain as he was led through
the booking process. Throughout, Lewellen asked to be taken back to Schneck for
medical treatment. But Lewellen was placed in a cell at the Jackson County Jail.
-5-
At 6:15 p.m., two hours after being discharged from the hospital, Defendant Dr.
John F. Alexander, a radiologist at Schneck, looked at Lewellen’s x-rays as part of a
second read quality control process. His report mentions the poor quality of the x-rays
and blames Lewellen’s lack of cooperation, but Alexander admitted in his deposition that
he had no reason to believe that that was the case. The report also states that
Lewellen’s spine had an ossific density left of the L1-L2 disc space that could be an
osteophyte,7 but a fracture “cannot be completely excluded” because the lateral view of
the lumber spine was not diagnostic, meaning that it was not clear enough to be useful.
According to protocol, if the radiologist notices something that the ER physician missed,
the radiologist needs to communicate with the ER physician. From the record, it
appears that Alexander contacted no one.
Yet there was something seriously wrong with Lewellen. He had a burst fracture
in his spine that was damaging his spinal nerves while he was being held in the Jackson
County Jail. Over the course of the night, Lewellen started to notice neurological
systems like numbness in his lower body. Despite the fact that Alexander and Reisert
claim not to be able to tell if there was a fracture from Lewellen’s x-rays, several other
doctors who have looked at them say that a fracture can be seen. These include
Alexander’s boss, Dr. Staib, who although he could understand how “an optical illusion”
could make a radiologist miss the fracture, in his deposition was asked: “if you got that
[x-ray] that night before you even looked at the lateral . . . you could tell, couldn’t you,
7 An osteophyte is also called a bone spur.
-6-
Doctor, that it was fractured?” The doctor responded: “I hope that I would be able to do
that.” (Staib Dep. 43.)
Dr. David Schwartz, an orthopedic surgeon at Methodist Hospital in Indianapolis,
who later performed surgery on Lewellen, was more blunt. In an affidavit submitted by
Lewellen, Schwartz claims that a burst fracture is clear from the x-rays taken at
Schneck on June 8. He writes: “There is nothing ambiguous about these x-rays. When
you put them on a view box, the fracture at L-2 is immediately apparent on both the AP
and lateral views.” (Schwartz Aff. ¶ 2.) Dr. Bennie Martin Fulbright, an orthopedic
surgeon, who treated Lewellen in Tennessee, also agrees that the fracture is visible
from the June 8 x-rays. (Fulbright Aff. ¶ 7.)
Lewellen passed several hours in jail with this, as of yet, undetected burst
fracture. Around 9:00 p.m. Officer McPherson went back to Lewellen’s holding cell to
check on another inmate. He saw Lewellen crying in pain and noticed that Lewellen
had urinated all over himself. Lewellen told McPherson that his back hurt around the L5
vertebrae. McPherson asked if Lewellen had any medical training and Lewellen
responded that he did.
McPherson left the cell to call the jail nurse, who, when informed that Schneck
had released Lewellen, instructed McPherson to give Lewellen some Tylenol.
Unsatisfied, McPherson called Schneck’s Emergency Department directly. He spoke
-7-
with Defendant Sharon Duffield8 who said she would check with a physician and call
McPherson back.
As promised, Nurse Duffield called McPherson back shortly after 11:00 p.m. and
said that someone had re-reviewed the x-ray and found an abnormality. For some
reason Duffield instructed McPherson not to notify Lewellen. It is unclear from the
record what the relationship between Schneck and the county jail was, but McPherson
testified in his affidavit that the department could not take Lewellen back to Schneck
unless Schneck “ordered” it. Despite notifying McPherson that there was an
abnormality in his x-ray, Duffield told McPherson not to bring Lewellen back to the
hospital and did not give any instructions as to a proper treatment.
Officer McPherson was so upset with the nurse’s response that he contacted the
jail commander imploring him to get medical help for Lewellen. The commander
suggested that since they could not transport a detainee to Schneck, they might release
Lewellen on his own recognizance. To do this, McPherson had to fill out paperwork for
an Own Recognizance Order and submit it to judge. This was done and an ambulance
was called to pick up Lewellen.
Before the ambulance arrived, McPherson went back to the holding cell to tell
Lewellen that medical help was being secured. He noticed blood on the wall of the cell
8 Although the report McPherson made contemporaneously listed the nurse’s name as
“Sandra” a reasonable jury could conclude that this nurse was Sharon Duffield. Nurse Duffield
was on call at the time and Officer McPherson claims to have received a call from Nurse
Duffield regarding this case in 2005.
-8-
and looked at Lewellen, finding a deep laceration on his arm that had not been treated
in any way. The cut still had grass and dirt in it.
At 1:00 a.m., June 9, 2003, Lewellen arrived back at Schneck. A CT scan of his
spine performed at Schneck revealed that during the night Lewellen spent in jail, a
fragment of bone from the burst fracture has displaced and was impinging on his spinal
column. Lewellen was later transported to Methodist Hospital in Indianapolis and was
operated on by Dr. David Schwartz.
Despite the operation, Lewellen suffered from permanent neurological defects as
a result of this injury. Lewellen cannot urinate or defecate on his own; he suffers from
some sexual dysfunction. Dr. Schwartz believes that had Lewellen been properly
treated on June 8, 2003, instead of discharged, he “more likely than not [] would have
remained neurologically intact.” (Schwartz Aff. ¶ 10.)
III.
Discussion
Lewellen sues four individuals and the hospital. He sues Duffield, Davis, Reisert,
and Alexander under 42 U.S.C. § 1983 for violating his Fourteenth Amendment rights
as a pretrial detainee to adequate medical care. He also sues the hospital for violating
the Emergency Medical Treatment and Labor Act (EMTALA), 42 U.S.C. § 1395dd. The
court will address the § 1983 claims first.
-9-
A.
42 U.S.C. § 1983
Lewellen sues two doctors and two nurses involved in his treatment at Schneck
from June 8-9, 2003, under 42 U.S.C. § 1983 for violating his Fourteenth Amendment
right to adequate medical care. When in the custody of state or local authorities, a
pretrial detainee is required to receive access to adequate medical care pursuant to the
Due Process Clause of the Fourteenth Amendment. Jackson v. Illinois Medi-Car, Inc.,
300 F.3d 760, 764 (7th Cir. 2002). A pretrial detainee’s due process right to medical
care is violated when a state official “acts with deliberate indifference toward the
detainee’s serious medical needs.” Qian v. Kautz, 168 F.3d 949, 955 (7th Cir. 1999)
(compiling several cases).
All four individual Defendants argue that they should be granted summary
judgment for the same three reasons. First, they are not state actors as required by the
Fourteenth Amendment and 42 U.S.C. § 1983. Second, Lewellen was not in state or
local custody while he received treatment at Schneck.9 Third, even construing the facts
most favorably to Lewellen, they were not deliberately indifferent to his serious medical
needs.
1.
State Action and Under Color of State Law
To be liable under 42 U.S.C. § 1983, not only must an individual violate a
plaintiff’s rights secured by the Constitution and laws of the United States, the individual
9 Dr. Reisert in contrast to the other Defendants did not argue in his brief that Lewellen
was not in state custody when he arrived at Schneck.
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must also be acting under color of state law. Case v. Milewski, 327 F.3d 564, 566 (7th
Cir. 2003) (citing West v. Adkins, 487 U.S. 42, 48 (1988)). The right secured by the
Constitution in this case is the right, guaranteed through the Fourteenth Amendment, to
adequate medical care for a pretrial detainee. Therefore, Defendants must also be
state actors because “it is well established that the Fourteenth Amendment ‘erects no
shield against merely private conduct, however discriminatory or wrongful.’” Wade v.
Byles, 83 F.3d 902, 904 (7th Cir. 1996) (quoting Blum v. Yaretsky, 457 U.S. 991, 1002
(1982)). Conduct that satisfies this state action requirement of the Fourteenth
Amendment will also satisfy the under color of state law requirement of § 1983. Lugar
v. Edmondson Oil Co., 457 U.S. 922, 935 (1982).
“[S]tate employment is generally sufficient to render the defendant a state actor .
. . .” Id. at 935 n.18; but see Polk County v. Dodson, 454 U.S. 312 (1981) (holding
public defender not a state actor). On the other hand, the actions of private parties
working as independent contractors for the state are not automatically transformed into
state actions, even if the contractor works exclusively for the government. Rendell-
Baker v. Kohn, 457 U.S. 830, 841 (1982).
Yet sometimes the action of an independent contractor is considered state
action. See, e.g., West, 487 U.S. at 57. The essential question is whether the
nominally private conduct is properly attributable to the state. Brentwood Academy v.
Tenn. Secondary Sch. Athletic Ass’n, 531 U.S. 288, 295 (2001); Lugar, 457 U.S. at 924.
This inquiry is a fact-intensive one that “is a matter of normative judgment, and the
criteria lack rigid simplicity.” Brentwood Academy, 531 U.S. at 295; see also Tarpley v.
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Keistler, 188 F.3d 788, 791 (7th Cir. 1999). As the Court has explained: “no one fact
can function as a necessary condition across the board for finding state action; nor is
any set of circumstances absolutely sufficient, for there may be some countervailing
reason against attributing activity to the government.” Brentwood Academy, 531 U.S. at
295-96. The Supreme Court has, however, listed three broad categories where it has
treated a nominally private entity as a state actor:
We have treated a nominally private entity as a state actor when it is
controlled by an “agency of the State,” Pennsylvania v. Board of Directors
of the City Trusts of Philadelphia, [353 U.S. 230, 231 (1957)] (per curiam),
when it has been delegated a public function by the State, cf., e.g., West
v. Atkins [487 U.S.] at 56; Edmonson v. Leesville Concrete Co., [500 U.S.
614, 627-628 (1991)], when it is “entwined with governmental policies,” or
when government is “entwined in [its] management or control,” Evans v.
Newton, [382 U.S. 296, 299 (1966)].
Id. at 296.
In this case, Defendant nurses are both employees of Schneck, a county-owned
hospital.10 While the court is mindful that not every action by a state employee is state
action, see, e.g., Perkins v. Rich, 204 F. Supp. 98 (D. Del. 1962) (police officer swearing
10 Dr. Alexander citing a district court case from South Carolina, Mitchell v. Chontos, 756
F. Supp. 243, 247-48 (D.S.C. 1990) (adopting report and recommendation of magistrate judge),
argues that Schneck itself is not a state actor. The court disagrees. A county-owned public
hospital, like a public school or a municipal park, is a state actor subject to the proscriptions of
the Fourteenth Amendment. Beedle v. Wilson, 422 F.3d 1059, 1070 (10th Cir. 2005)
(“Subsequent cases from our court have held, with little fanfare, that public trust and county
hospitals are properly deemed state actors for § 1983 purposes.”); McKeensport Hosp. v.
Accreditation Council for Graduate Med. Educ., 24 F.3d 519, 528 (3d Cir. 1994) (“Courts
commonly hold a state agency, like a county hospital district, for example, is a state actor even
though it is not engaged in actions that are traditionally the exclusive province of the state.”);
see also Dunn v. Washington County Hosp., 429 F.3d 689, 692 (7th Cir. 2005) (analyzing
county hospital’s actions as if a state actor).
-12-
out complaint as private citizen not state action), Plaintiff alleges that his constitutional
rights were violated by the nurses’ actions related to their government employment, not
their private conduct. This is generally enough to show that they exercised power
“possessed by virtue of state law and made possible only because the wrongdoer is
clothed with the authority of state law.” West, 487 U.S. at 49; see also Lugar, 457 U.S.
at 935-36 n.18.
Nurses Davis and Duffield argue that their actions cannot be attributed to the
state and that “[a]ny attempt to attribute their actions to the State simply on the basis of
their employment by Schneck Medical Center is feeble.” (Defs.’ Br. 10.) Defendants
argue that if, as a general rule, Davis’s and Duffield’s conduct is considered state
action, state-employed nurses everywhere will be subject to § 1983 suits from
dissatisfied patients. Whether or not nurses’ potential exposure to § 1983 suits is really
as great as Defendants contend, this has not protected public school teachers and
officials who violate students’ constitutional rights from liability, e.g., Doe v. Smith, 470
F.3d 331, 340-41 (7th Cir. 2006) (public school teacher acting under color of law when
he sexually abused student). Neither should it protect state-employed nurses who
violate patients’ constitutional rights.
Unlike Davis and Duffield, Defendant doctors are not nominally employees of the
hospital or the County. Like most doctors working for hospitals, Defendants are
employed as independent contractors. See Sylvia A. Law, Do We Still Need A Federal
Patients’ Bill of Rights, 3 Yale J. Health Pol’y L. & Ethics 1, 15 (2002). At the time of
Plaintiff’s treatment at Schneck, Dr. Reisert was an employee of Jackson County
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Emergency Physicians, a private entity which contracted with Schneck to provide
physician services at the Emergency Department. Dr. Alexander was an employee of
Dr. Staib, who in turn was an independent contractor with Schneck to provide
radiological services.
Plaintiff argues that although Reisert and Alexander are nominally private actors,
their actions in this case are properly attributable to the state. In support of his
argument, Plaintiff cites West v. Adkins, 487 U.S. 42. In West, the Supreme Court held
that a physician who contracted with the prison system to provide medical services to
prisoners could be a state actor for the purposes of the Eighth Amendment. Id. at 54.11
The court explained that although the contractual relationship between the doctor and
state was not the same as other state employees, “[i]t is the physician’s function within
the state system, not the precise terms of his employment, that determines whether his
actions can fairly be attributed to the State.” Id. at 55-56. In essence, the state
delegated an affirmative constitutional obligation—medical treatment for inmates—to Dr.
Adkins, who, in performing this function, was a state actor. Id. at 56.
As the Supreme Court explained, there were significant policy reasons for finding
state action. As a prisoner, West could only receive medical treatment from someone
approved by the state to treat him. As the Court explained:
11 The analysis for an Eighth Amendment claim for failure to provide adequate medical
care to an inmate is the same as a Fourteenth Amendment claim for failure to provide adequate
medical care to a pretrial detainee. See infra.
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If Doctor Adkins misused his power by demonstrating deliberate
indifference to West’s serious medical needs, the resultant deprivation
was caused, in the sense relevant for state-action inquiry, by the State’s
exercise of its right to punish West by incarceration and to deny him a
venue independent of the State to obtain needed medical care.
Id. at 55. If a doctor who contracts with the state to provide inmate medical care is not
liable under § 1983, inmates are “deprive[d] . . . of the means to vindicate their Eighth
Amendment rights.” Id. at 56. Importantly in West: “[1] The State bore an affirmative
obligation to provide adequate medical care to West; [2] the State delegated that
function to respondent Atkins; and [3] respondent voluntarily assumed that obligation by
contract.” Id.
Dr. Reisert urges that emergency services, like those performed in this case, are
distinguishable from the in-prison physician services in West. He cites Sykes v.
McPhillips, 412 F. Supp. 2d 197 (N.D.N.Y. 2006) (Hurd, J.), where the district court
granted summary judgment for defendant physician on a § 1983 claim because he was
not a state actor. Plaintiff inmate was brought to a private hospital where defendant
was an emergency room doctor. Id. at 199. Plaintiff claimed that defendant physician
was deliberately indifferent to his serious medical needs. Id. at 200. Defendant claimed
that he was not a state actor; plaintiff argued that the private hospital regularly treated
inmates, the physician contracted with the hospital to provide emergency services, and
could, therefore, expect to treat inmates. Id. at 203. Further, defendant knew plaintiff
was an inmate when he treated him. Id.
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The court rejected this argument relying partly on another Northern District of
New York case in front of the same judge, Nunez v. Horn, 72 F. Supp. 2d 24 (N.D.N.Y.
1999) (Hurd, J.). In Nunez, defendant physician performed orthopedic surgery on an
inmate in a private hospital; the court granted summary judgment for defendant
because he was not a state actor. The court distinguished West because the physician
performed the surgery not in a prison hospital—“subject to all of the pressures and
constraints resulting from security concerns”—but in a private hospital—“a much more
physician-controlled environment.” Id. at 27. Also the physician in Nunez had not
contracted with the Bureau of Prisons or the state to provide services to inmates. Id.
The court in Sykes found that these reasons applied in the case before it plus an
additional reason: while the physician in Nunez accepted the inmate as a referral, the
physician in Sykes had one encounter with the inmate for emergency treatment. Sykes,
412 F. Supp. 2d at 204. As the district court in Sykes explained in holding that the
private hospital was also not a state actor, federal EMTALA law requires a hospital
participating in the federal Medicare program to treat all patients who arrive at the
emergency department. Id. at 203. “Willingness to accept patients under these
circumstances cannot be construed, even impliedly, as contracting to provide
emergency medical services [for inmates].” Id.
In Sykes, the court reasoned that the strong policy reasons for holding the
physician to constitutional standards were outweighed by the fact that the private
hospital and doctors were conscripted through EMTALA to accept every patient whether
a prisoner or not. Id. (“However compelling this policy concern, it is not likely that
-16-
Congress intended to confer state actor status through this interpretation of EMTALA
and there is no indication in West that the Supreme Court would extend the scope of
such status to all providers of care to prisoners without an express contract.”). The
court need not discuss the persuasiveness of that finding, however, because the court
agrees with Plaintiff that the reasoning of Sykes is inapplicable to this case because
Schneck, unlike the hospitals in those cases, is public.12
The strong normative reasons for finding state action in this case as articulated in
West are not offset by any other policy. The concern in Sykes of confusing conscription
of private actors through EMTALA with a private actor voluntarily accepting
responsibility for a public function is not applicable here. Schneck is a public hospital
that ultimately shares a constitutional responsibility to provide pretrial detainees with
medical care. Even without EMTALA or an express contract with the State Police, it
would have to treat pretrial detainees presented to it within the bounds of the Fourteenth
Amendment.13 That Schneck delegated its constitutional responsibility to treat pretrial
detainees to independent contractors—parties who voluntarily accepted the delegation
12 Plaintiff also argues that Schneck’s medical staff worked in concert with the jail staff
and that for this reason, the doctors should be considered state actors. Plaintiffs point to Dr.
Reisert’s testimony that his released Lewellen into a “watched atmosphere” and was aware that
the jail would not take prisoners with blood alcohol levels above .30%. But this is hardly a
sufficient nexus between the state and private actors to attribute their actions to the state. Cf.
Brokaw v. Mercer County, 235 F.3d 1000, 1016 (7th Cir. 2000) (listing elements to establish §
1983 liability through a conspiracy theory).
13 Further, there appeared to be some sort of delegation accepted by Schneck—after
all, Officer McPherson testified that he could not transport Lewellen to Schneck unless “ordered”
by Schneck personnel.
-17-
through contract—should not deprive Plaintiff of a chance to vindicate his constitutional
rights.
Further, the court respectfully disagrees with the Northern District of New York
that there is any meaningful distinction between situations like Nunez and West based
on where the inmate is treated. While the Court in West mentioned the effect of the
correctional setting on professional judgment, 487 U.S. at 56 n.15, this court is more
persuaded by Conner v. Donnelly, 42 F.3d 220 (4th Cir. 1994). In Conner v. Donnelly,
the United States Court of Appeals for the Fourth Circuit reversed summary judgment in
favor of defendant doctor on the issue of state action, despite the fact that the doctor did
not have a contractual relationship with the state. The defendant doctor saw plaintiff
inmate on referral from the prison physician. Id. at 221-22. Although the physician
treated the inmate outside of the prison environment, the court found this distinction
irrelevant, noting: “It is the physician’s function while working for the state, not the place
where he performs his duties, that determines whether he acts under color of state law.”
Id. at 226. Further, “it is irrelevant . . . that Donnelly treated Conner in his office, where
he treats regular patients. . . . Donnelly acted under color of state law, not because he
treated Conner differently than other patients, but because the state authorized him to
treat Conner in order to fulfill the state’s constitutional obligation toward Conner.” Id.14
14 In his brief, Dr. Reisert attempted to distinguish Conner by noting that defendant
doctor in that case was reimbursed by the state, whereas Lewellen’s insurance paid for his
treatment at Schneck. However, this is irrelevant. That Lewellen was billed and paid for his
treatment does not alter the fact that the state was constitutionally obligated to provide him
access to medical treatment if he was a pretrial detainee.
-18-
Drs. Reisert and Alexander argue that there was no agreement between them
and the state to treat inmates and pretrial detainees. However, they were employed by
private entities that themselves voluntarily contracted with the state to provide general
medical services. Although from the evidence before the court it is not clear whether
either entity contracted specifically to treat inmates or pretrial detainees, in reality,
treating these types of patients was part of what they did under their contracts with the
state. It should not matter that the entirety of Defendants’ contract with the state was
not dedicated to performing affirmative constitutional obligations of the state. Cf. West,
487 U.S. at 56 (“It is the physician’s function while working for the State, not the amount
of time he spends in performance of those duties or the fact that he may be employed
by others to perform similar duties, that determines whether he is action under color of
law.”)
A trier of fact could determine the obligation to treat pretrial detainees and
inmates was delegated to defendant doctors through Schneck. If part of the doctors’
contractual duties is a public function, the doctors should be held to the same
constitutional standards that the state itself is prior to its delegation. It should not matter
that this public function was not explicitly stated in the contract; as long as it was a
necessary (and presumably foreseen) part of fulfilling the contract, the independent
contractors voluntarily accepted the public function delegated to them.
It is for these reasons that a trier of fact could find that the relationship between
the state and the nominally private conduct in this case is functionally identical to that in
West. Indiana has an affirmative duty under the Fourteenth Amendment to provide
-19-
pretrial detainees with medical care. To fulfill its obligation, it took Lewellen to Schneck,
another arm of the state. Schneck in turn delegated its affirmative obligation to the
entities that employed Defendant doctors. Through their contract with the state, these
employers voluntarily assumed the responsibility. Therefore, the court cannot say as a
matter of law that Defendant doctors were not state actors.
This is not to say that as a matter of law, they were. This highly factual analysis
must be submitted to a trier of fact to determine whether given the circumstances of the
relationship between the hospital, the state, and the independent contractors that a
public function was delegated to Defendant doctors and, thus, that their actions in
performing it are properly attributable to the state. What is important at this stage of the
proceedings is that a reasonable trier of fact might determine that the Defendant were
state actors; therefore, on this issue, the Plaintiff survives summary judgment.
2.
Custody15
Defendants argue that even if they are state actors, Lewellen was not in custody
when he arrived at Schneck on June 8, 2006. Therefore, because the state has no
15 Only Dr. Alexander denied that Lewellen was in police custody in his answer; all other
defendants, including Nurses Davis and Duffield, admitted that Lewellen was in police custody.
(See Reisert Answer, Doc. 26, ¶ 43; Alexander Answer, Doc. 27, ¶ 43; Duffield, Schneck, Davis
Answer, Doc. 28, ¶ 43). However, Nurses Davis and Duffield argued in their brief that Lewellen
was not in police custody as part of their denial that they were state actors. To the extent that
their judicial admission in the answer does not cover this argument, the court includes this
section.
-20-
affirmative duty to provide emergency medical services, see Hill v. Shobe, 93 F.3d 418,
422 (7th Cir. 1996), Lewellen’s constitutional rights were not violated regardless of
whether Defendants were deliberately indifferent to Lewellen’s serious medical needs.
In Salazar v. Chicago, 940 F.2d 233 (7th Cir. 1991), the Seventh Circuit affirmed
a directed verdict against defendant police officers and for defendant paramedics. The
court began by addressing the preliminary question of whether plaintiff was in custody.
Id. at 237.16 Plaintiff was in a motor vehicle accident while intoxicated and treated by
paramedics at the accident scene while police officers were present. Id. He later died
and his estate sued the paramedics and officers alleging they were deliberately
indifferent to his serious medical needs. Id. at 235. The court framed the question of
custody as: “whether Salazar was in custody, or, more precisely, free to leave and seek
help on his own while the paramedics treated him.” Id. at 237. The court treated this as
a factual issue and noted: “Although [an officer] did not formally arrest [plaintiff] until
after the paramedics left, it may be that [the officers] would not have let [plaintiff] go, and
that the paramedics knew that [plaintiff] was not free to leave.” Id.
A jury would have ample evidence to find that Lewellen was in custody while at
the hospital. First, Lewellen presented evidence that the police would not have let him
go while he was being treated at Schneck. Most importantly, when Lewellen begged to
be allowed to stay and receive treatment after he was discharged, he was taken to jail.
16 Although the analysis was technically dicta because the paramedic-defendants in the
case eventually conceded that plaintiff should be treated as a pretrial detainee, the framework
developed by the Seventh Circuit in the case is still useful.
-21-
It could be inferred, then, that the troopers would not have let him go to receive
treatment from another provider of his choosing half an hour earlier during his
treatment. Also, in the probable cause determination paperwork, the police noted the
time of arrest at 2:22 p.m., or the time they arrived at the accident scene; this is a good
indication that in their mind, Lewellen was not free to leave during his stay at Schneck.
Second, Lewellen presented evidence that the staff knew he was in custody
during his treatment at Schneck. The police were present at the hospital waiting for
Lewellen to be discharged. When nurse Davis had trouble getting Lewellen to sign his
discharge papers, she went to Trooper Drew and asked him to sign them. This is a
clear sign that she believed the officers had custody and that Lewellen was not free to
go. According to Plaintiff’s facts, nurse Duffield had to know Lewellen was in custody
when she spoke with Officer McPherson because McPherson was calling from the jail
asking if he should bring Lewellen back to Schneck. A reasonable jury could determine,
given these facts, that Lewellen was not free to leave and seek help on his own.
Defendants point out that Lewellen did not receive his Miranda warnings or
notice of arrest until the time of discharge. But custody and formal arrest are not the
same thing. See id. As long as Lewellen was not free to seek medical help on his own,
he was in custody for purposes of a pretrial detainee’s Fourteenth Amendment right to
medical care. Defendant Reisert additionally argued in his brief that the Lewellen’s
insurance was billed for the medical treatment rather than the state. This fact is hardly
dispositive. A trier of fact could still find that, given all of the other facts in favor of
-22-
finding custody, Lewellen’s paying for the service does not prove that he was free to
seek medical care on his own.
3.
Deliberate Indifference
Finally Defendants argue that even construing the facts in Lewellen’s favor, they
were not deliberately indifferent to his serious medical needs. A pretrial detainee is
entitled to access to adequate medical care by the Fourteenth Amendment. City of
Revere v. Mass. Gen. Hosp., 463 U.S. 239, 244 (1983). The rights of pretrial detainees
“are at least as great as the Eighth Amendment protection available to a convicted
prisoner.” Estate of Cole by Pardue v. Fromm, 94 F.3d 254, 259 (7th Cir. 1996).
Therefore, courts analyze a Fourteenth Amendment claim for denial of medical services
under the Eighth Amendment standard. Higgins v. Corr. Med. Servs. of Ill., Inc., 178
F.3d 508, 511 (7th Cir. 1999).
In order to prevail under the Eighth Amendment or the Fourteenth Amendment
on a claim for denial of medical services, a prisoner or detainee must show “deliberate
indifference to a prisoner’s serious illness or injury.” Estelle v. Gamble, 429 U.S. 97,
104 (1976). Meeting this standard requires both an objective and a subjective element.
Objectively, a condition must be serious, meaning “the failure to treat [the] condition
could result in further significant injury or the unnecessary and wanton infliction of pain.”
Gutierrez v. Peters, 111 F.3d 1364, 1373 (7th Cir. 1997). Subjectively, the defendants
must have acted with deliberate indifference, in other words, they “[knew] of and
disregard[ed] an excessive risk to [detainee’s] health or safety; the official must both be
-23-
aware of facts from which the inference could be drawn that a substantial risk of serious
harm exists, and [they] must also draw the inference.” Farmer v. Brennan, 511 U.S.
825, 837 (1994).
A showing of negligence on the part of the official will not be enough to show
deliberate indifference. Estelle, 429 U.S. at 106. “Medical malpractice does not
become a constitutional violation merely because the victim is a prisoner.” Id. On the
other hand, plaintiffs do not have to show that the officials intended for the inmate to
suffer harm. Haley v. Gross, 86 F.3d 630, 641 (7th Cir. 1996). “It is enough to show
that the defendants actually knew of a substantial risk of harm to the inmate and acted
or failed to act in disregard of that risk.” Walker v. Benjamin, 293 F.3d 1030, 1037 (7th
Cir. 2002) (citing Haley, 86 F.3d at 641). This may be established by showing that “the
danger was objectively so great that actual knowledge of the danger could be inferred.”
Duckworth v. Franzen, 780 F.2d 645, 653 (7th Cir. 1985); see also Farmer, 511 U.S. at
842.
That Lewellen satisfied the objective part of the test is beyond question. He
arrived at Schneck on June 8, 2003, with an unstable burst fracture in his lower spine.
Failure to treat the condition not only could lead to further significant injury, it did. Dr.
Schwartz wrote in his affidavit that had Lewellen been treated properly rather than
hastily discharged, he might have avoided any neurological damage. (Schwartz Aff. ¶
10.) In their briefs, Defendants do not argue this part of the test.
-24-
They do argue that they were not deliberately indifferent to this serious medical
need. Defendant nurses argue that Lewellen failed to produce any evidence that they
knew about his condition. Without a showing that they actually knew he had a serious
medical need, the failure to treat him is merely negligent, which does not rise to the
level of a Constitutional violation. Snipes v. De Tella, 95 F.3d 586, 590-91 (7th Cir.
1996). But knowledge may be inferred “when the medical professional’s decision is
such a substantial departure from accepted professional judgment, practice, or
standards as to demonstrate that the person responsible did not base the decision on
such a judgment.” Estate of Cole, 94 F.3d at 262.
Plaintiff has demonstrated that there is a genuine issue of material fact on
whether Dr. Reisert was deliberately indifferent to Lewellen’s serious medical needs.
According to evidence presented by Plaintiff, Dr. Reisert knew that Plaintiff had been in
an automobile accident and was complaining of back pain. However, the x-rays that Dr.
Reisert ordered were being printed off almost contemporaneously to Lewellen’s
discharge. Two doctors, Drs. Schwartz and Fulbright, testified that a burst fracture is
clearly visible on the x-rays that were being printed off as Lewellen was discharged. As
explained above, a trier of fact could use this evidence to determine that Dr. Reisert
ordered Lewellen discharged before even looking at these x-rays. Given that Plaintiff
was in an automobile accident and was in such visible agony that a State Trooper
questioned the decision to discharge Lewellen, discharging Lewellen without looking at
an x-ray was such a deviation from accepted professional judgment that a trier of fact
-25-
could easily determine that Dr. Reisert did not base his decision to discharge Plaintiff on
it. The § 1983 claim against Dr. Reisert survives summary judgment.
Given his role at the hospital, there is also a genuine issue of material fact as to
whether Dr. Alexander was deliberately indifferent to Lewellen’s serious medical needs
despite Dr. Alexander’s not looking at Plaintiff’s x-rays until after he was discharged.
According to Dr. Staib, who at the time was Dr. Alexander’s boss, the reason for a
second read of the x-rays is to verify that the initial read by the Emergency Department
doctor, in this case Dr. Reisert, was correct. (Staib Dep. 121, 125.) If the radiologist
reaches a different conclusion than the initial read, that result must be conveyed to the
ordering physician. Dr. Staib testified that this is usually done first by telephone and
then that notification is documented. According to Dr. Staib: “Unexpected positive
results should be communicated directly and that communication should be
documented.” (Id. at 130.)
Upon reviewing Lewellen’s x-rays, Dr. Alexander claimed that he could not rule
out a burst fracture. Dr. Staib testified that the type of result that Dr. Alexander found in
Lewellen’s x-rays is that type of result that should have been directly communicated.
(Id.) There is no doubt that it was not; however, Dr. Alexander claims that he put the
notes in the hospital’s system for anybody to look at and that this is enough under
hospital policy to fulfill any duty he had. Given Dr. Staib’s testimony, a trier of fact could
determine that it was not enough.
-26-
Further, a trier of fact could determine that Dr. Alexander had enough information
about Lewellen’s situation for his failure to do more than post his notes to constitute
deliberate indifference. First, there is enough evidence for a trier of fact to determine
that Dr. Alexander was aware of a risk of Plaintiff having a burst fracture and aware of a
risk of that fracture getting worse, yet did nothing but passively issue an equivocal
report without specifically notifying anyone. Plaintiff claims that there is enough
evidence for a trier of fact to determine that in the face of evidence that Plaintiff had a
burst fracture, Dr. Alexander deliberately reported an equivocal reading of Plaintiff’s x-
rays in order to save the hospital embarrassment. But even if a trier of fact does not go
that far, it could easily determine that Dr. Alexander was aware of a significant risk that
Lewellen had burst fracture. Dr. Alexander himself admitted he knew there was at least
a small risk. (Alexander Dep. 128-29.) Several doctors presented testimony that the
burst fracture was obvious from the x-rays Dr. Alexander viewed the night of June 8,
2003. Dr. Alexander claimed that what he saw could be an osteophyte, but that a
fracture could not be excluded. But Dr. Schwartz testified that no radiologist could
confuse the fracture on the x-ray for an osteophyte. (Schwartz Aff. ¶ 2.)
Dr. Alexander argues that even with knowledge of a risk to Lewellen, he was not
deliberately indifferent to the serious medical needs to a pretrial detainee because he
was not subjectively aware of the ramifications of his inaction. In reality, Dr. Alexander’s
inaction carried significant consequences because Lewellen was in custody without
access to medical care while bone fragments in his spine were causing permanent
damage. Had Dr. Alexander attempted to contact Dr. Reisert or the Jackson County
-27-
Jail to tell them either that more tests needed to be done because the previous results
were inconclusive or that treatment should begin for a burst fracture, perhaps Lewellen
would not have experienced any permanent damage.
But what is critical for the subjective prong of the deliberate indifference analysis
is that Dr. Alexander was actually aware of these risks when he failed to notify Dr.
Reisert or the Emergency Department of his findings. Dr. Alexander claims that he
never knew that Lewellen was in custody while at the hospital or that he was taken to
jail after he was released. Rather, he claims that he assumed that Lewellen was still in
the hospital awaiting the diagnostic results. Perhaps Dr. Alexander, although aware of
the risk to Lewellen, assumed that if Lewellen were still in significant pain a CT scan
could reveal any fracture and that there was little risk of further harm to Lewellen while
being watched in the hospital.
Yet a trier of fact could determine that Dr. Alexander is not being truthful about
what he knew of Lewellen’s situation that night. First, Dr. Alexander did not originally
mention any of this in his deposition or his original affidavit. He originally claimed to
have no memory of Lewellen’s case at all and has subsequently added these key facts
about what he assumed about Lewellen’s remaining in the hospital. A trier of fact could
infer that contrary to Dr. Alexander’s claims, he did know that Lewellen was in custody
and discharged from the hospital and therefore disregarded a serious risk to a pretrial
detainee’s health by doing nothing but post his equivocal report. Dr. Alexander wrote in
-28-
his contemporaneous report that Lewellen was drunk and combative.17 Schneck is also
a small, rural hospital with one Emergency Department Doctor on duty and one
radiologist on duty at the time Lewellen was originally brought to the hospital. It is not a
far leap to infer that Dr. Alexander was aware of the circumstances of Lewellen’s
drunken, supposedly combative interaction with hospital staff that afternoon, including
his being taken away by the police. Had Dr. Alexander looked at Lewellen’s hospital
records, he could have determined that Lewellen was discharged from the hospital and
did not sign his discharge papers. Perhaps these types of interactions take place all the
time at Schneck and radiologists are completely unaware of the circumstances, but this
is a question of fact not to be decided on summary judgment. Given this, a trier of fact
could determine that Dr. Alexander’s failure to do anything but post his equivocal report
on the hospital system was demonstrating deliberate indifference to Lewellen’s serious
medical needs.
As for the nurses, they both argue that their duty was to obey the orders of
physicians and to notify the physicians of any changes in the patient’s condition. This,
they argue, is exactly what they did. According to Davis, Dr. Reisert released Lewellen
and she was only obeying his orders. But Davis cannot rely on the doctor’s release to
abdicate all her responsibility when Lewellen’s needs were so obvious.
17 Dr. Alexander also wrote that additional tests could be performed when the patient
was less agitated. It could be argued that this demonstrates his belief that Lewellen was still in
the hospital. However, it is equally consistent with knowledge that a patient is in police custody
and can be ordered back to the hospital for additional tests.
-29-
The Eighth Circuit in Coleman v. Rahija, 114 F.3d 778 (8th Cir. 1997), upheld the
verdict from a bench trial finding a nurse deliberately indifferent to the serious medical
needs of an inmate who went into premature labor. Plaintiff, seven months pregnant,
had a history of premature labor. When she had bloody show, she was transferred from
the Iowa Medical and Classification Center (“IMCC”), where defendant was a nurse, to
the University of Iowa Hospitals. The University determined that she was not in active
labor and released her to the IMCC, but instructed that she should return to the
University “if her contractions became painful, regular, and separated by ten minutes or
less.” Id. at 782. The next day at 7:00 pm, plaintiff had extreme pain in her lower
abdomen and reported to the prison nurse who told her to return when the contractions
were six to seven minutes apart. At 9:30 pm, she returned claiming her contractions
were six minutes apart, but defendant could not feel any contractions. Plaintiff returned
to her living unit and “sat on the edge of her bed in increasing pain until 11:25 pm.” Id.
at 783. Finally, she started screaming in pain and laid in the fetal position on the floor.
When the nurses came, they still could not feel any contractions. But when they asked
her to stand, she expelled fifteen cubic centimeters of dark red blood. They then
transferred her to the University where her baby was born.
The trial court found that defendant was deliberately indifferent through her
unnecessary delay in transferring plaintiff to the University. Defendant argued that she
was following the doctors’ instructions that plaintiff not be returned to the hospital until
her contractions were painful, regular and separated by ten minutes or less. Despite
the doctor’s instructions, the district court concluded that defendant had actual
-30-
knowledge based on the obviousness of plaintiff’s serious medical need. The circuit
court held that this conclusion was not clearly erroneous. The court explained:
[Plaintiff’s] propensity for precipitous labor and premature delivery was
well-documented and expressly noted by prison officials in Coleman’s
medical records, to which [defendant] had been exposed, and constituted
the sole reason for Coleman’s placement at IMCC. From this evidence, a
trier of fact could have found that [defendant] had actual knowledge of the
risk of pre-term labor.
Id. at 786.
The same inference can be made in the case of Nurse Davis. When Trooper
Drew saw Lewellen at the hospital, Lewellen “was insistent that the hospital had not
examined him sufficiently and that he had terrible pain in his lower back.” (Drew Aff. ¶
7.) Drew even asked Nurse Davis directly if the hospital was done examining him. (Id.)
Nurse Davis’s response was that Lewellen was just drunk and that of course he would
have some pain after a motor vehicle accident. But Lewellen was in such pain that he
could not put any weight on his legs and had to be put into a wheelchair. Nurse Davis
was present for all of this. Trooper Drew observed Lewellen in so much pain that he
deviated from standard practice and cuffed him in the front rather than the back.
Trooper Drew also specifically told the jailers upon dropping Lewellen off that despite
the hospital’s release, Lewellen was in so much pain that someone should keep a close
eye on him. (Drew Aff. ¶ 11.)
Given the amount of pain that Drew observed, Lewellen’s inability to place any
weight on his legs, and his pleading to Nurse Davis that he was in tremendous pain and
-31-
needed to see a doctor, the jury could conclude that Davis was aware of Lewellen’s
serious medical need. She need not have looked at Lewellen’s x-ray to know that there
was something wrong, especially given the fact that the Trooper Drew and Officer
McPherson seemed to know something was wrong. There were numerous red flags
waving from which a jury could conclude that Nurse Davis was deliberately indifferent to
a serious medical need of Lewellen.
Given the facts surrounding Nurse Duffield’s phone conversation with Officer
McPherson, a trier of fact could also determine that she was deliberately indifferent.
Defendant Duffield first argues that she was not the nurse that spoke with Officer
McPherson. She points out that the police log detailing the conversation claims that the
nurse’s name was “Sandra”, while her name is “Sharon.” But this question of fact must
be construed in favor of Plaintiff. The trier of fact could find that nurse McPherson
spoke with was Duffield, and not some other nurse named Sandra, given that those
names are similar and that Duffield was working at the time. Officer McPherson also
claims that he received a call from Duffield herself essentially admitting that she was the
one who spoke with him and scolding McPherson for telling others what she had said
that night.
Nurse Duffield certainly knew that Lewellen had a serious medical condition
because she herself informed the police that Lewellen’s x-ray came back with an
abnormality. Bizarrely, according to McPherson, she instructed the police not to tell
Lewellen of this result and specifically told Officer McPherson not to bring Lewellen
back to Schneck. Officer McPherson further claims that he could not take Lewellen to
-32-
Schenck without someone there ordering him; Defendants present no evidence to
counter his statement. Given that, a reasonable jury could find Nurse Duffield acted
with deliberate indifference when she called to present this information without working
in any way to provide assistance. She knew that there was an abnormality in his x-ray
and she knew that Lewellen could not leave the jail to receive his own medical care.
There are many possible explanations for her behavior that would stop short of
deliberate indifference; however, Defendants have presented no evidence which would
preclude a jury as a matter of law from concluding that it was simply deliberate
indifference that caused her to act the way she did. Therefore, a jury will be allowed to
make that determination. The motion for summary judgment is DENIED as to all the §
1983 claims against the individual Defendants.
B.
EMTALA
Plaintiff also presents a claim against Schneck under the Emergency Medical
Treatment and Active Labor Act (“EMTALA”). Schneck argues that it should receive
summary judgment on this claim because even construing the facts in Lewellen’s favor,
they met the requirements of EMTALA. In the alternative, Schneck seeks partial
summary judgment ruling that the caps on recovery under Indiana’s Medical Malpractice
Act work to limit Schneck’s liability to $250,000.
-33-
1.
Substance of the EMTALA Claim
The Emergency Medical Treatment and Active Labor Act (EMTALA) was passed
to combat the problem of “patient dumping;” that is, the practice of transferring or
discharging indigent or non-insured patients while their emergency conditions worsen.
Johnson v. Univ. of Chi. Hosps., 982 F.2d 230, 233 n.7 (7th Cir. 1993). There are two
requirements for certain federally-funded hospitals under EMTALA. First, a hospital
“must provide for an appropriate medical screening examination within the capability of
the hospital’s emergency department . . . to determine whether or not an emergency
medical condition . . . exists” 42 U.S.C. § 1395dd(a).18 Second, if an emergency
18 The relevant portion of 42 U.S.C. § 1395dd reads:
(a) Medical Screening Requirement
In the case of a hospital that has a hospital emergency department, if any
individual (whether or not eligible for benefits under this subchapter) comes to
the emergency department and a request is made on the individual’s behalf for
examination or treatment for a medical condition, the hospital must provide for an
appropriate medical screening examination within the capability of the hospital’s
emergency department, including ancillary services routinely available to the
emergency department, to determine whether or not an emergency medical
condition (within the meaning of subsection (e)(1) of this section) exists.
(b) Necessary stabilizing treatment for emergency medical conditions and labor
(1) In general
If any individual (whether or not eligible for benefits under this subchapter) comes
to a hospital and the hospital determines that the individual has an emergency
medical condition, the hospital must provide either–
(A) within the staff and facilities available at the hospital, for such further medical
examination and such treatment as may be required to stabilize the medical
condition, or
(B) for transfer of the individual to another medical facility in accordance with
(continued…)
-34-
medical condition is detected by this screening, the patient may not be discharged until
he or she has received a stabilizing treatment or transferred when certain criteria are
met. § 1395dd(b)(1), (c). The statute authorizes a patient harmed by a hospital’s failure
to adhere to either of these two requirements to sue the hospital. § 1395dd(d)(2).
A hospital is only required to stabilize an emergency medical condition that they
actually know about. Vickers v. Nash Gen. Hosp., Inc., 78 F.3d 139, 145 (4th Cir.
1996). Schneck claims that it performed an appropriate medical screen and thus that
the stabilization requirement was not triggered. Therefore, although Lewellen presents
two separate claims under EMTALA, one for screening, the other for stabilization, they
necessarily collapse into one. The court need only analyze Lewellen’s screening claim.
If Schneck fulfilled the screening requirement, then the stabilization claim necessarily
fails too because the stabilization requirement was not triggered. If Schneck did not
fulfill the screening requirement, it is liable and there is no need to analyze the
stabilization requirement separately.
EMTALA is not a national medical malpractice statute imposing a standard of
care on hospital emergency rooms. See Brooks v. Maryland Gen. Hosp., Inc., 996 F.2d
708, 713 (4th Cir. 1993). A hospital that conducts an appropriate medical screen yet
fails to detect, or misdiagnoses, an emergency medical condition—even if negligent and
liable under medical malpractice—is not liable under EMTALA. Bryant v. Adventist
18(…continued)
subsection (c) of this section.
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Health Sys./W., 289 F.3d 1162, 1166 (9th Cir. 2002); Marshall on Behalf of Marshall v.
E. Carroll Parish Hosp. Serv. Dist., 134 F.3d 319, 322-23 (5th Cir. 1998).
“EMTALA aims at disparate treatment.” Brooks, 996 F.2d at 713. Therefore, a
patient must show that he was treated differently from other patients. Williams v.
Birkeness, 34 F.3d 695, 697 (8th Cir. 1994). The Ninth Circuit explained in Jackson v.
East Bay Hospital, 246 F.3d 1248, 1256 (9th Cir. 2001) there are two ways to prove an
inappropriate screening:
We hold that a hospital satisfies EMTALA’s “appropriate medical
screening” requirement if it provides a patient with an examination
comparable to the one offered to other patients presenting similar
symptoms, unless the examination is so cursory that it is not “designed to
identify acute and severe symptoms that alert the physician of the need for
immediate medical attention to prevent serious bodily injury.”
Id. (quoting Eberhardt v. City of Los Angeles, 62 F.3d 1253, 1257 (9th Cir. 1995)).
Defendants correctly point out that Plaintiff presented no evidence that the
screen performed on him differed from any other patient’s screen. However, a
reasonable jury could conclude that the screen performed was so cursory that it was not
designed to identify acute and severe symptoms and thus did not meet the
requirements of EMTALA. In its brief, Schneck barely argues Reisert’s screen was
more than cursory. Schneck argues only that Reisert did something and found
Lewellen had a normal neurological exam. Defendants claim: “Based upon his
examination, Dr. Reisert brought to bear on the case his medical judgment and
concluded Mr. Lewellen could be safely discharged.” (Defs.’ Br. 19.)
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But according to the evidence presented by the Plaintiffs, the x-rays ordered by
Dr. Reisert were being printing off as Lewellen was being discharged. A jury could
conclude that either Dr. Reisert did not even bother to look at them or looked at them so
casually that he missed what two other physicians said was obvious: that the x-rays
demonstrate that Lewellen had a burst fraction in his spine. If Reisert did not study the
x-rays how could his screen be designed to identify acute and severe symptoms?
Lewellen’s stay at the hospital was alarmingly brief considering he was in a motor
vehicle accident and complaining of severe back pain so bad he could not stand or sit in
a chair correctly. Lewellen still had a bleeding gash in his arm with grass and dirt in it
when he arrived at prison. The court is mindful that EMTALA’s screening requirement
means something more than an inadvertent failure to follow the regular screening
process in a particular case. Cf. Summers v. Baptist Med. Cen. Arkadelphia, 91 F.3d
1132, 1139 (8th Cir. 1996) (citing Correa v. Hosp. San Francisco, 69 F.3d 1184, 1192-
93 (1st Cir. 1995). But this scenario is so grave that a jury could conclude that rather
than a negligent deviation from normal practice, the screening requirement was simply
not met. For this reason, Schneck’s motion for summary judgment will be DENIED.
2.
Medical Malpractice Act
Schneck argues that if the EMTALA claim survives summary judgment, the court
should rule that Indiana’s Medical Malpractice Act limits Lewellen’s total recovery to
$1.25 million and Schneck’s liability to $250,000. EMTALA authorizes suit for personal
harm but limits the damages recoverable to “those damages available for personal
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injury under the law of the State in which the hospital is located.” 42 U.S.C. §
1395dd(d)(3)(A).
Two cases decided in the Southern District of Indiana have held that this
language commands that limits on damages under Indiana Medical Malpractice Act
apply to EMTALA claims that fall within Indiana’s definition of malpractice. See Valencia
v. St. Francis Hosp. & Health Ctr., No. 1:03-cv-0252-LJM-WTL, 2004 WL 963712 (S.D.
Ind. March 1, 2004) (McKinney, C.J.); Reid v. Indianapolis Osteopathic Med. Hosp., 709
F. Supp. 853 (S.D. Ind. 1989) (Barker, J.). Some United States Court of Appeals
decisions have also held state medical malpractice damage limits applicable to
EMTALA claims. See Smith v. Botsford Gen. Hosp., 419 F.3d 513 (6th Cir. 2005);
Power v. Arlington Hosp. Ass’n, 42 F.3d 851 (4th Cir. 1994).
Indiana’s Medical Malpractice Act limits the “total amount recoverable for an
injury or death of a patient” to “$1,250,000.” Ind. Code § 34-18-14-3(a)(3). However, a
qualified health care provider is “not liable for an amount in excess of two hundred fifty
thousand dollars ($250,000) for an occurrence of malpractice.” § 34-18-14-3(b). A
patient’s compensation fund makes up “[a]ny amount due from a judgment or settlement
that is in excess of the total liability of all liable health care providers . . . .” § 34-18-14-
3(c). A surcharge levied on all health care providers is deposited into the fund. § 34-
18-6-1.
Defendant argues that if the previous rulings of the Southern District are
followed, these damage limits should be applied and, thus, Schneck can be liable for no
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more than $250,000.19 Although Plaintiff asks the court to hold differently than the
opinions of Chief Judge McKinney and Judge Barker, the court is reaching the same
result as those and like the Fourth and Sixth Circuits concludes that the medical
malpractice limits should apply to cap Plaintiff’s recovery.
Plaintiffs argue that the plain language of the EMTALA statute should be applied,
meaning that the medical malpractice caps would not be incorporated. According to
Plaintiffs, the legislative history of EMTALA contains references to medical malpractice;
therefore, Congress was familiar with the term and chose not to apply it. The statute
indicates that “those damages available for personal injury” rather than a specific
reference to medical malpractice. In Indiana, there are no general limits to the amount
recoverable for personal injury. Plaintiffs also argue that the language of the provision
is permissive rather than prohibitive and thus should not be read as overly restrictive.
But these arguments are not persuasive in the face of the legislative history of
EMTALA. In Power v. Arlington Hospital Association, the Fourth Circuit looked at the
legislative history and found that Congress intended—contrary to Plaintiff’s
assertion—for medical malpractice caps to apply, when applicable to the claim by state
law. A broad phrase like “personal injury” was used, the court wrote, “so that it would
19 Neither of previous opinions from the Southern District addressed how the patient’s
compensation fund relates to EMTALA. Judge Barker’s opinion in Reid v. Indianapolis
Osteopathic Medical Hospital incorporated the qualified provider limit ($100,000 at the time,
$250,000 now) without a discussion of whether the patient’s compensation fund would make up
any excess liability. See Reid, 709 F. Supp. at 854. Chief Judge McKinney’s opinion
discussed only the higher total patient recovery limit ($1.25 million) and did not express an
opinion on whether the qualified provider limit would also apply to the hospital. See Valencia,
2004 WL 963712 at *5.
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not be necessary to delineate each and every type of limitation on damages, e.g.,
limitations on punitive damages, noneconomic losses, and malpractice damages caps,
that the states might have enacted.” Power, 42 F.3d at 862. The House Committee on
the Judiciary expressed concern about “‘the potential impact of these enforcement
provisions on the current medical malpractice crisis.’” Id. (quoting H.R. Rep. No. 241,
99th Cong., 1st Sess., pt. 3, at 6). In particular, the Committee noted the impact of
severe penalties on hospitals in rural and poor areas. Id. When the Conference
Committee modified the bill to its final form, it commented “[t]he courts are directed, on
the issue of damages, to apply the law of the State in which the violating hospital is
located, for actions brought by a harmed individual . . . .” Id. (quoting H.R. Conf. Rep.
No. 99-453, 99th Cong., 1st Sess., 131 Cong. Rec. H13093, H13226 (daily ed. Dec. 19,
1985)). So, as noted by the Power court, the reference in EMTALA to damages
available in the state where the hospital is located was appropriately broad to cover all
types of state law limits on damages.
Judge Barker of this court also noted in Reid that:
Congress “was clearly aware of a growing concern in some states that
excessive damage awards were fueling a medical malpractice ‘crisis,’” and
that Congress apparently wished to preserve state-enacted ceilings on the
amount of damages that could be covered in EMTALA through the
incorporation of § 1395dd(d)(2)(A).
Id. (quoting Reid, 709 F.Supp. at 903-04).20
20 The statute itself also contains a provision about preemption of state law, § 1395dd(f)
states that EMTALA does not preempt state law unless the state law “directly conflicts with a
(continued…)
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But the more critical analysis is how Indiana law treats the type of conduct of
which the plaintiff complains. In other words, does Indiana law limit the damages from
medical treatment as a personal injury? Clearly it does. See Ind. Code § 34-18-14-3.
In Indiana, malpractice is defined as “a tort or breach of contract based on health care
or professional services that were provided, or that should have been provided, by a
health care provider.” Ind. Code § 34-18-2-18. This is a broad definition, but does not
include every claim of a patient against a health care provider. See, e.g., Pluard v.
Patients Compensation Fund, 705 N.E.2d 1035, 1041-42 (Ind. Ct. App. 1999) (falling
surgical lamp improperly installed not a health care issue); Methodist Hosp. of Ind., Inc.
v. Ray, 551 N.E.2d 463, 466 (Ind. Ct. App. 1990) (contracting Legoinnaire’s disease
while patient not a situation unique to hospitals); Doe v. Madison Ctr. Hosp., 652 N.E.2d
101, 104-05 (Ind. Ct. App. 1995) (sexual assault by counselor “cannot be recast to
speak in the language of medical malpractice.”).
In his brief, Lewellen does not argue that this case is outside Indiana’s definition
of medical malpractice and, therefore, not subject to its damage limitations. So, the
court need not explore this issue in depth, but the court notes that Lewellen’s injuries
appear to be firmly within the Medical Malpractice Act and thus should be subject to the
Medical Malpractice Act’s limits on damages. Yet Lewellen argues that for policy
reasons, the court should apply the Act’s limits piecemeal, applying only the $1.25
million total patient recovery cap, not the $250,000 qualified provider cap. In other
20(…continued)
requirement of this section.” In his brief, Plaintiff does not argue that the medical malpractice
cap directly conflicts with a requirement of EMTALA.
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words, Schneck, despite the fact it would only be liable for $250,000 under the Medical
Malpractice Act should be liable for all damages up to $1.25 million. Lewellen claims
that he can not petition the patient’s compensation fund to make up any difference
between Schneck’s $250,000 limit and any additional damages up to $1.25 million. If
Schneck can only be liable for $250,000, the Act’s $1.25 million cap is meaningless as
applied to EMTALA claims falling within the Act. Indiana Code § 34-18-14-3(b), Plaintiff
claims, must be read in light of 3(c), which says that any excess liability must be paid by
the patient compensation fund.
Applying the $250,000 limit to Schneck rather than the $1.25 million total liability
limit makes more sense than applying bits and pieces of the Medical Malpractice Act
limitations, given the legislative history cited in Power. Congress, concerned with the
weight of excessive judgments on rural institutions, like Schneck, incorporated the
state’s limitations on claims to limit EMTALA claims that would have been limited under
state law. The State of Indiana limits any provider’s liability on a malpractice claim to
$250,000. While part of that scheme includes a patient’s compensation fund that
makes up the excess liability, it appears that Congress intended EMTALA damages to
fit within the limits of that system. For these reasons, Defendant Schneck’s motion for
partial summary judgment will be GRANTED.21
21 Further, Lewellen’s premises are suspect. First, it is not clear that the Fund could not
be petitioned to pay out the excess damages on an EMTALA claim. For example, the
Wisconsin Supreme Court has held that its patient’s compensation fund must pay on EMTALA
claims. Burks v. St. Joseph’s Hosp., 569 N.W.2d 391, 402 (Wis. 1999). In Patient’s Comp.
Fund v. Hicklin, 823 N.E.2d 705 (Ind. Ct. App. 2005), a patient petitioned the Fund after settling
with a hospital on both his EMTALA and medical malpractice claim. (Although the Court of
Appeals of Indiana held that the patient’s estate could not access the fund, the reason was
(continued…)
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IV.
Conclusion
The Fourteenth Amendment does not proscribe private conduct in any way;
therefore, a violation requires state action. However, a trier of fact could find all four
individual Defendants to be state actors. Further, a trier of fact could find that all four
were deliberately indifferent to Lewellen’s serious medical needs. Therefore,
Defendants’ motions for summary judgment on the § 1983 claim will be DENIED.
Plaintiff also presented enough evidence to survive summary judgment on his EMTALA
claim against Defendant hospital and that motion will also be DENIED. However, the
damages caps of the Indiana Medical Malpractice Act will apply to limit Schneck’s
potential EMTALA liability to $250,000.
The Court has concluded that there is not a need for oral argument on the
Motions for Summary Judgment, therefore, the Request for Oral Argument (Document
No. 57) is DENIED.
ALL OF WHICH IS ORDERED this 16th day of August 2007.
John Daniel Tinder, Judge
United States District Court
21(…continued)
because the settlement agreement was structured as a periodic payment plan with a present
value of less than the policy amount.) Second, it is likely that Lewellen would be limited to
$1.25 million for all claims he might bring related to his treatment at Schneck (the EMTALA
claim and any medical malpractice claims) because there is only one injury in this case. See
Ind. Code § 34-18-14-3. Therefore, any doctor liable under a medical malpractice theory would
also be liable for an additional $250,000. Lewellen is not really limited to $250,000, as he
claims.
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Copies to:
Magistrate Judge William G. Hussmann, Jr.
William David Bridgers
NEAL & HARWELL PLC
dbridgers@nealharwell.com
Gary J. Clendening
MALLOR CLENDENING GRODNER & BOHRER
gjclende@mcgb.com
Kristen Vanderkooi Dyer
NEAL & HARWELL PLC
kdyer@nealharwell.com
Philip Norman Elbert
NEAL & HARWELL PLC
pelbert@nealharwell.com
Christopher Charles Hagenow
HOPPER & BLACKWELL
chagenow@hopperblackwell.com
Kirk Robert Jocham
HALL RENDER KILLIAN HEATH & LYMAN
kjocham@hallrender.com
Belinda Rose Johnson
MALLOR CLENDENING GRODNER & BOHRER LLP
bjohnson@mcgb.com
Edward J. Liptak
CARSON BOXBERGER
liptak@carsonboxberger.com
Christopher L. Riegler
HALL RENDER KILLIAN HEATH & LYMAN
criegler@hallrender.com
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