Published by Arfaa Law Group
Medical malpractice claims against government entities, such as the Federal Bureau of Prisons (BOP), are often difficult to establish due to strict legal requirements under the Federal Tort Claims Act (FTCA). This was highlighted by a recent decision out of Maryland in which the court ultimately upheld a finding that the plaintiff did not meet the burden of proof for his claims. If you or a loved one has suffered harm due to medical negligence in a correctional facility, you should talk to an experienced Baltimore medical malpractice attorney to clarify your legal rights.
Case Setting
It is reported that the plaintiff, an inmate in federal custody since 2009, filed suit against the United States and the Federal Bureau of Prisons, alleging medical malpractice under the FTCA. The plaintiff had been diagnosed with open-angle glaucoma before entering custody, and his vision was already substantially impaired at the time of his incarceration. Over the years, he underwent multiple transfers between facilities and received various treatments, including eye surgeries and prescription eye drops.
It is alleged that the plaintiff sought consistent medical assistance to administer his prescription eye drops, which he claimed were necessary to prevent further vision deterioration. He also requested additional accommodations, including braille instruction, darker tinted glasses, and a specialized lock for visually impaired individuals. The plaintiff contended that the failure to provide him with these accommodations, as well as the delay in scheduling a recommended laser surgery, directly contributed to his worsening eyesight.
Following a five-day bench trial, the district court ruled against the plaintiff, concluding that he had failed to prove that the BOP’s medical staff breached the applicable standard of care. The plaintiff appealed, arguing that the district court erred in its findings regarding his FTCA medical malpractice claim.
Establishing Medical Malpractice Under the FTCA
On appeal, the court whether the district court correctly concluded that the plaintiff failed to establish medical malpractice under South Carolina law, which governs FTCA claims arising in that state. To succeed in a medical malpractice case, a plaintiff must prove by a preponderance of the evidence that: a doctor-patient relationship existed; the healthcare provider deviated from recognized medical standards; the deviation caused harm to the patient; and the plaintiff suffered damages as a result.
The court focused on two main allegations: the delay in scheduling the plaintiff’s laser eye surgery and the failure to provide consistent assistance with his eye drops. The plaintiff asserted that the delay in surgery resulted in further vision deterioration and that he was physically unable to self-administer his prescribed medication.
The court found that the district court’s ruling was well-supported by expert testimony. The defense’s expert, an ophthalmologist, testified that the delay in performing the surgery did not constitute a breach of the standard of care and did not significantly contribute to the plaintiff’s vision loss. The district court found this testimony credible and persuasive, rejecting the plaintiff’s expert’s contrary opinion.
With regard to the plaintiff’s claim that he required assistance in administering his eye drops, the district court found that the plaintiff had demonstrated the ability to self-administer the medication but often refused to do so. The court credited expert testimony that legally blind individuals could typically administer their own eye drops and concluded that the BOP’s failure to provide daily assistance was not a deviation from the standard of care.
The court emphasized that disagreement between medical experts does not, in itself, establish medical malpractice. Courts generally defer to trial judges on credibility determinations, and here, the district court had found the BOP’s expert testimony more compelling. Because the plaintiff failed to prove that the BOP’s medical staff acted negligently, the appellate court upheld the dismissal of his FTCA claim.
Talk to a Seasoned Baltimore Medical Malpractice Attorney
Medical malpractice claims against government healthcare providers present unique legal challenges. If you or a loved one has suffered due to inadequate medical treatment, it is in your best interest to talk to an attorney about your options. At Arfaa Law Group, our seasoned Baltimore medical malpractice attorneys are committed to advocating for victims of medical negligence. Call us today at (410) 889-1850 or complete our online form to schedule a consultation.