Marc Hall v. US, No. 20-6848 (4th Cir. 2022)Annotate this Case
Plaintiff is an inmate at United States Penitentiary (“USP”) Hazelton who filed a pro se civil action in United States district court alleging violations under the Federal Tort Claims Act (“FTCA”) for denied and delayed medical care of his chronic illnesses. Plaintiff also filed a Motion for Leave to Proceed in forma pauperis (“IFP”). Following the Magistrate Judge’s recommendation, the district court denied Plaintiff’s IFP motion on the grounds that he did not meet the “imminent danger of serious physical injury” exception. Plaintiff now appealed to the Fourth Circuit.
The Fourth Circuit vacated the district court’s judgment and remanded. The court explained that a plain reading of the statute requires that litigants allege sufficient specific facts to demonstrate a nexus between the claims presented and the imminent danger alleged. Here, both parties agree that it is a “commonsense requirement that a prisoner’s allegation of imminent danger must relate to their underlying claims.” Moreover, the Government concedes that “a fairly traceable relationship exists between Plaintiff’s alleged imminent danger and the claims set forth in his FTCA complaint, as they both arise from his allegations of delay and denial of medical treatment.” Plaintiff has passed this threshold because he alleged that the prison’s continued denial and delay in providing medical treatment are directly causing his worsening physical and medical conditions which present an imminent danger of serious physical injury.
Finally, the court remanded writing that the district court did not have access to Defendant’s medical records and, thus, did not have a complete record to determine whether Defendant satisfied the “imminent danger” exception based on the court's clarified standard.
This opinion or order relates to an opinion or order originally issued on August 10, 2022.