Khanis-Orion Morningstar v. James H. Smith, Jr., Doctor, Wellpath; Charlotte Gardner, Regional Ombudsman, Wellpath; Aundrea Culclager; Brandy Johnson
July 7, 2026·25-2845·Panel Decision·By Aisha Johnson
The Eighth Circuit affirmed the district court's grant of summary judgment in a pro se civil rights action brought by an Arkansas inmate. The court held that the inmate failed to establish deliberate indifference to his serious medical needs or valid claims for failure to supervise.
Arkansas inmate Khanis-Orion Morningstar filed a pro se action under Section one thousand nine hundred eighty-three of Title forty-two of the United States Code. He appealed the district court’s adverse grant of summary judgment against him.
The court’s reasoning
Upon de novo review, the court agreed with the district court that Morningstar did not establish that defendants were deliberately indifferent to his serious medical need. The unrebutted affidavit from defendants’ expert established that the treatment of conservative observation was appropriate, even if Morningstar disagreed with it. The court also agreed that, absent underlying constitutional violations, the failure-to-supervise claim against defendant Gardner failed. Additionally, the official-capacity claims against Wellpath failed.
What it means going forward
The affirmation reinforces that pro se plaintiffs must provide more than disagreement with medical treatment to prove deliberate indifference when expert testimony supports the defendants’ actions.
