Snow v. McDaniel

The district court incorrectly grants a defendant’s summary judgment motion where material issues of fact remain as to whether the denial of hip replacement surgery for a death-row inmate amounted to "deliberate indifference," in violation of his Eighth Amendment rights.

John Snow, a death-row inmate, brought § 1983 claims against various doctors and wardens in the Nevada Department of Corrections (collectively, “Defendants”) for declaratory and injunctive relief, and damages for Eighth Amendment violations due to “deliberate indifference” to his medical needs. The district court granted Defendants’ motion for summary judgment, disregarding the magistrate’s recommendation that an issue of material fact existed regarding the adequacy of Snow’s medical treatment. Snow appealed. The Ninth Circuit found that a policy to disregard death-row inmates’ serious medical conditions may have motivated the decision to treat Snow pharmacologically and to deny authorization for hip replacement surgery, despite specialists’ recommendations otherwise. The Court also held that the district court incorrectly granted summary judgment on the basis that there existed only a disagreement of medical opinion. Issues of fact still remained as to whether it was medically acceptable for Defendants to have continuously refused to authorize Snow’s hip replacement surgery, or if they acted deliberately indifferent towards his medical needs. REVERSED in part, AFFIRMED in part, and REMANDED.