The U.S. Court of Appeals for the Tenth Circuit on Thursday ruled that three medical professionals at a Colorado prison violated an inmate’s constitutional rights and may therefore be sued.
Seifullah Chapman, who was released in 2018 from the Administrative Maximum facility in Florence, has severe Type 1 diabetes, requiring special medical care, and is at risk for related disorders that result in a 10% to 15% mortality rate. His life is endangered if he does not receive between three and six shots of insulin per day.
Judge Jerome A. Holmes, writing for the three-judge appeals panel, found “considerable record evidence” that the defendants — George Santini, Anthony Osagie, and Ronald Camacho — provided Chapman care that was “dramatically short of medically acceptable standards ... even for prisoners.”
“While at ADX," Holmes described, "Mr. Chapman suffered serious bouts of hypoglycemia and hyperglycemia multiple times a week — often several days in a row — as well as multiple life-threatening bouts of extreme hypoglycemia."
The court did not dismiss outright the defendants’ argument that staffing and security circumstances outside their control contributed to their ability to care for Chapman, but it nevertheless agreed that they violated the Eighth Amendment prohibition on cruel and usual punishment.
Describing Chapman’s care as so poor that it may have caused him brain injury, Holmes added that “the record strongly suggests that Mr. Chapman’s care at ADX was ‘contrary to...basic human rights and the community standards of care.’”
In ruling that the medical workers violated clear legal standards, the court listed the incidents for which the defendants could be held personally liable, including a two-hour delay in returning with sliding scale insulin after Chapman slipped into severe hyperglycemia when he felt his blood was “on fire.” Normally, qualified immunity prevents public employees from being sued for the performance of their duties.
The case is Seifullah Chapman v. George Santini, MD, et al.
Editor's note: This story has been updated to correct that Seifullah Chapman was released from prison in 2018 and to correct the spelling of Anthony Osagie's name.