WILLIAMS v. RYAN (2021)

United States Court of Appeals, Ninth Circuit.2021-06-30No. No. 20-17274

Summary · law.co

Holding. The court affirmed the district court's summary judgment because Williams failed to establish a genuine factual dispute regarding whether the defendant acted with deliberate indifference to his medical needs.

Arizona inmate Woodie Leo Williams, Jr. filed a federal civil rights lawsuit under 42 U.S.C. § 1983 against correctional officials, claiming they were deliberately indifferent to a serious leg wound. The district court granted summary judgment against Williams, finding insufficient evidence of deliberate indifference. The appellate court reviewed the case fresh and upheld the lower court's decision.

For deliberate indifference to medical needs to succeed, a prisoner must demonstrate that a prison official both knew of and consciously disregarded a substantial risk to his health. The court clarified that mere negligence or disagreement over medical treatment does not meet this standard. Additionally, a delay in receiving medical care only constitutes deliberate indifference if it results in significant harm to the prisoner.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether a prison official's response to an inmate's leg wound constituted deliberate indifference to serious medical needs
Standard for deliberate indifference: knowledge plus conscious disregard of substantial risk
Whether negligence or medical disagreement satisfies the deliberate indifference standard
Whether delay in medical treatment alone establishes deliberate indifference without significant injury

Procedural posture

Williams appealed pro se from the district court's grant of summary judgment in his § 1983 medical indifference claim against correctional officials.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

Arizona state prisoner Woodie Leo Williams, Jr. appeals pro se from the district courts summary judgment in his 42 U.S.C. § 1983 action alleging deliberate indifference to his serious medical needs. We have jurisdiction under 28 U.S.C. § 1291. We review de novo, Toguchi v. Chung, 391 F.3d 1051, 1056 (9th Cir. 2004), and we affirm.

The district court properly granted summary judgment because Williams failed to raise a genuine dispute of material fact as to whether defendant Nicole Schaffer was deliberately indifferent to the wound on his leg. See id. at 1057-60 (a prison official acts with deliberate indifference only if he or she knows of and disregards an excessive risk to the prisoners health; negligence and a mere difference in medical opinion are insufficient); Hallett v. Morgan, 296 F.3d 732, 745-46 (9th Cir. 2002) (a delay in medical treatment does not constitute deliberate indifference unless the delay led to significant injury).

We reject as without merit Williamss contention that defendants answering brief was untimely.

We do not consider arguments and allegations raised for the first time on appeal. See Padgett v. Wright, 587 F.3d 983, 985 n.2 (9th Cir. 2009).

AFFIRMED.