In Maryland, people seeking treatment from a healthcare provider have the right to expect competent care, even if incarcerated. If they subsequently receive substandard care, and suffer harm as a result, they may be able to pursue claims against the parties responsible for their harm, but establishing liability can be challenging, as demonstrated in a recent Maryland case. If you or a loved one has been harmed due to inadequate medical treatment, it is in your best interest to consult a knowledgeable Baltimore medical malpractice attorney who can help you understand your rights and options.
Factual Background and Procedural History
It is reported that the plaintiff, an inmate at a Maryland correctional facility, filed a lawsuit alleging both medical malpractice and deliberate indifference to his serious medical needs. The plaintiff contended that facility medical providers failed to diagnose and properly treat his pulmonary sarcoidosis for over a year. According to the allegations, he first presented with a persistent dry cough, chest pain, and breathing difficulties in May 2016. He was initially prescribed an expectorant and later an albuterol inhaler, but his symptoms did not improve.
It is alleged that medical personnel ordered diagnostic tests, including chest x-rays and a pulmonary evaluation at the University of Maryland Medical System (UMMS). A CT scan performed in March 2017 reportedly suggested pulmonary sarcoidosis, yet subsequent biopsies were inconclusive. The plaintiff was not definitively diagnosed until an endobronchial ultrasound in July 2017 confirmed granulomatous lymphadenitis, a condition associated with sarcoidosis. He was then prescribed prednisone in August 2017, which allegedly improved his symptoms.
The plaintiff argued that the failure to diagnose and treat his condition in a timely manner constituted medical malpractice under Maryland law. He further alleged that medical personnel failed to investigate whether his sarcoidosis had spread to other organs, despite his complaints of lumps in his eye and testicle. Because these symptoms reportedly improved after he was prescribed prednisone, he claimed that earlier intervention would have prevented prolonged suffering.
Adequately Pleading Medical Malpractice Claims
On review, the district court evaluated whether the plaintiff had presented a viable claim for medical malpractice. Under Maryland law, medical malpractice claims require plaintiffs to demonstrate: (1) the existence of a doctor-patient relationship; (2) a breach of the standard of care; (3) causation; and (4) damages. The court found that the plaintiff failed to establish that the defendants deviated from the applicable standard of care in diagnosing and treating his condition.
The court acknowledged that pulmonary sarcoidosis is a complex condition that often eludes early diagnosis due to its nonspecific symptoms. While the plaintiff argued that the delay in diagnosis constituted negligence, the court noted that misdiagnosis or delayed diagnosis alone is insufficient to prove malpractice. Instead, a plaintiff must show that a physician acted unreasonably in failing to diagnose or treat a condition in accordance with established medical practices. The court found that the defendants had conducted numerous diagnostic tests, referred the plaintiff to specialists, and ultimately provided appropriate treatment. The delays in diagnosis, the court concluded, were not attributable to negligence but rather to the inherent challenges of identifying pulmonary sarcoidosis.
Furthermore, the court emphasized that disagreements over treatment choices or allegations of suboptimal medical care do not necessarily equate to medical malpractice. Maryland law requires expert testimony to establish the standard of care and prove that a deviation from that standard directly caused harm. The plaintiff, however, did not provide expert testimony supporting his claims, which further weakened his case.
Because the plaintiff failed to demonstrate that the defendants’ actions constituted a deviation from the standard of care, the court dismissed the medical malpractice claim along with the Eighth Amendment deliberate indifference claim.
Talk to a Skilled Baltimore Medical Malpractice Attorney
Medical malpractice claims require a thorough understanding of legal and medical principles. If you or a loved one has suffered harm due to negligent medical care, whether inside or outside of a correctional facility, it is critical to seek experienced legal counsel. At Arfaa Law Group, our skilled Baltimore medical malpractice attorneys are dedicated to advocating for victims of medical negligence. Call us today at (410) 889-1850 or complete our online form to schedule a consultation and discuss your legal options.