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Wadev.Georgia Correctional Health, LLC

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.21-14275
Decided2024-07-10
ReporterNo. 21-14275 (11th Cir. 2024)
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
Eleventh CircuitEighth AmendmentDeliberate IndifferencePrison Medical CareQualified ImmunityMens ReaSummary JudgmentTales From the CryptBehind Bars
Case Summary

A prisoner missed prescribed seizure medication for four days and suffered seizures that allegedly caused permanent injury. His estate sued correctional and medical employees for deliberate indifference. Resolving tension in circuit precedent under the prior-panel-precedent rule, the Eleventh Circuit applied the more-than-gross-negligence formulation and required proof of subjective awareness and a sufficiently culpable disregard of a serious medical risk. Although the record showed serious communication failures and careless conduct, it did not establish the required state of mind for any defendant or a basis for supervisory liability. The court affirmed summary judgment for all defendants.

Opinion

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Wade v. Georgia Correctional Health, LLC — The Atlanta Gleaner