Four women incarcerated at Michigan's Huron Valley Correctional Facility sued state corrections officials and Wayne State medical officers over a scabies infestation that plagued the prison from 2016 to 2019. The inmates alleged they suffered from painful rashes and "unbearable itching" while prison officials relied on Corizon Health contractors who initially misdiagnosed the condition. The outbreak affected nearly 200 women—almost 10% of the prison population—before an outside dermatologist, Dr. Walter Barkey, finally identified live mites in skin scrapings and confirmed the scabies diagnosis in late 2018.
Writing for the majority, Circuit Judge Murphy found that while the inmates adequately pleaded deliberate indifference claims, no precedent would have clearly warned non-treating prison officials that relying on medical contractors' diagnoses violated the Eighth Amendment. "Prison officials do not act with deliberate indifference to a prisoner's medical needs when they 'rely on medical judgments made by medical professionals responsible for prisoner care,'" Murphy wrote, citing established precedent that generally protects officials who defer to medical expertise.
The district court had previously denied the officials' motion for judgment on the pleadings, finding that the complaint adequately alleged constitutional violations and that qualified immunity should not apply. The court also rejected state-law immunity claims, concluding that the inmates sufficiently alleged the officials were the proximate cause of their injuries under Michigan's Government Tort Liability Act.
The appeals court's split decision leaves open several claims, including injunctive relief requests against the officials and all claims against Corizon Health defendants. Circuit Judge White wrote a lengthy dissent arguing that the officials had years to respond appropriately and that existing precedent provided sufficient notice that their conduct violated constitutional rights, particularly given the "abysmal" track record of contractor Corizon Health.