Background
Timothy Sneed appealed a district court order granting Dr. Alexis Acosta-Martinez’s motion for summary judgment. Sneed, proceeding pro se, alleged that the medical director violated his Eighth Amendment right to adequate medical care by being deliberately indifferent to his serious medical needs.
The court’s reasoning
The court reviewed the summary judgment order de novo. It held that the record evidence showed no genuine dispute as to any material fact. The court found that Sneed’s foot problems were mild based on x-rays, contradicting his declaration of severe pain. Furthermore, Sneed failed to provide medical evidence to support his claim that the delay in treatment exacerbated his condition.
There is no genuine dispute about whether Sneed’s foot pain was a serious medical need because the x-rays show that Sneed’s foot problems were mild.
USCA11 Case: 25-11385 Document: 22-1 Date Filed: 04/15/2026 Page: 3 of 4
What it means going forward
The decision reinforces that pro se litigants must provide specific, corroborating medical evidence to survive summary judgment in Eighth Amendment deliberate indifference claims.