Jacob Pfaller v. Mark Amonette, No. 21-1555 (4th Cir. 2022)
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Plaintiff’s estate sued the Virginia Department of Corrections (“Department”) and several prison officials under 42 U.S.C. Section 1983 and Virginia law, alleging that they violated the Eighth Amendment and state law by failing to provide Plaintiff treatment for his chronic hepatitis C until it was too late.
Defendants in this appeal are Dr. A and Dr. W. Plaintiff alleges that Dr. A designed treatment guidelines for inmates with hepatitis C that unconstitutionally excluded Plaintiff from receiving treatment. Plaintiff also alleges that Dr. W failed to follow those guidelines and committed both medical malpractice and Eighth Amendment violations in denying him appropriate treatment. Defendants unsuccessfully moved for summary judgment, alleging that they were protected by qualified immunity and, on Dr. W’s part, derivative sovereign immunity.
The Eighth Circuit reversed the district court’s denial of sovereign immunity to Dr. W and denial of qualified immunity to Dr. A but affirm its denial of qualified immunity to Dr. W. The court declined to hold that Dr. A was clearly on notice that he should have ordered the Department’s primary care providers to prescribe this novel treatment rather than referring patients to specialists for treatment. Further, the court explained a prisoner’s purported right not to be subjected to a treatment regimen that prioritized antiviral treatment to prisoners with the most advanced levels of fibrosis was not clearly established when Dr. A designed the Guidelines in 2015. Moreover, three of the four factors strongly weigh in favor of sovereign immunity, and one only moderately weighs against it. Therefore, the court concluded that the district court erred by rejecting Dr. W’s sovereign-immunity defense.
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