Published by Arfaa Law Group
Claims arising from medical care provided in correctional facilities frequently straddle the line between medical malpractice and constitutional law. Courts must determine not only whether care was appropriate, but whether alleged deficiencies rise to the demanding level of deliberate indifference under the Eighth Amendment. A recent decision from the United States District Court for the District of Maryland examined these issues in the context of cataract surgery provided to an incarcerated individual who objected to the use of artificial lenses. If you believe you were harmed by inadequate medical treatment while incarcerated in Maryland, it is important to consult with a Baltimore medical malpractice attorney who can evaluate whether your claims are viable under state or federal law.
Facts and Procedural History
Allegedly, the plaintiff, who was incarcerated at a Maryland correctional institution, suffered from progressively worsening vision due to cataracts and sought medical treatment through prison health services. He was evaluated by outside specialists and informed that cataract surgery would involve the removal of the natural lens and the implantation of an artificial lens.
It is alleged that, after returning to the correctional facility, the plaintiff informed medical staff that he objected to having any artificial material implanted in his body and consented only to the removal of the cataracts. Despite these objections, cataract extraction surgeries were later performed on both eyes, and artificial intraocular lenses were implanted during the procedures.
Reportedly, following surgery, the plaintiff experienced eye irritation, continued vision issues, and a need for corrective lenses. He asserted that the surgery was performed against his wishes and that the outcome was unsatisfactory. Based on these events, the plaintiff filed a civil rights action, asserting that multiple medical providers and correctional officials violated his constitutional rights.
It is reported that the defendants moved for summary judgment, arguing that the plaintiff had received medically appropriate care, that cataract surgery with lens implantation is the standard procedure, and that any disagreement with treatment or dissatisfaction with the outcome did not amount to deliberate indifference. The court also considered supplemental filings addressing the timing of the surgery, changes in medical contractors, and the applicable ophthalmology guidelines.
Medical Malpractice in the Institutional Settings
The court analyzed the claims under the Eighth Amendment standard governing deliberate indifference to serious medical needs. It first addressed the objective component, recognizing that cataracts and significant vision impairment can constitute a serious medical condition requiring treatment. The court then turned to the subjective component, which requires proof that defendants knew of and disregarded an excessive risk to the plaintiff’s health.
Applying this framework, the court found no evidence that the defendants acted with reckless disregard. The record demonstrated that the plaintiff was evaluated, referred to specialists, and ultimately received cataract surgery, which the court recognized as a medically accepted treatment for his condition. The fact that the surgery included implantation of artificial lenses did not support a constitutional claim, as this method represents the standard approach to cataract removal.
The court emphasized that disagreements between a patient and medical providers regarding the course of treatment do not establish deliberate indifference. Even assuming the plaintiff objected to the specific manner in which the surgery was performed, such allegations sound in negligence or medical malpractice, not constitutional wrongdoing. The court further noted that inmates do not possess a constitutional right to the treatment of their choice, only to treatment that is medically necessary and reasonably provided.
The court also rejected any claim based on delay in treatment, finding no evidence that the defendants ignored applicable medical guidelines or intentionally withheld care. To the contrary, the record showed that referrals and evaluations were initiated and that surgery was performed once medically indicated. Because the plaintiff failed to produce evidence that any defendant knowingly disregarded a serious medical risk, the court granted summary judgment in favor of all defendants and ordered the case closed.
Consult with a Knowledgeable Baltimore Medical Malpractice Attorney
If you or a loved one believes inadequate medical care caused harm in a correctional or institutional setting, you should consult an attorney about your legal options. The knowledgeable Baltimore medical malpractice attorneys at Arfaa Law Group can assess your case and advise you of what measures to take to protect your interests. We represent injured parties throughout Baltimore and across Maryland. You can contact us through our online contact form or by calling (410) 889-1850 to schedule a consultation.