Phoenix v. Amonette, No. 22-6313 (4th Cir. 2024)
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The United States Court of Appeals for the Fourth Circuit addressed a case where an inmate with celiac disease sued a doctor for depriving him of a gluten-free diet. The district court had granted summary judgment to the doctor because the plaintiff did not have an expert witness to testify about the standard treatment for celiac disease or the causal link between the doctor’s conduct and the plaintiff’s alleged harm. The appeals court held that no expert testimony was needed to avoid summary judgment in this case. The court found that the plaintiff had presented sufficient evidence to create a genuine dispute of material fact about the doctor's knowledge of his celiac disease and the excessive risk it posed by failing to respond reasonably, even without an expert.
The court also clarified that expert testimony is not necessary to establish an Eighth Amendment claim of deliberate indifference. The court held that while determining whether medical professionals responded reasonably to a particular risk can involve an examination of the relevant standard of care, the fact that expert testimony may be necessary in some cases does not mean it was in this one. The court vacated the district court’s judgment and remanded the case for further proceedings.
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