Case Explained: CASSIOPIA RHOADS v. ERIK RIDDELL; JESSICA WHITAKER and SOUTHERN HEALTH PARTNERS, INC.; ROBERT J. WILLIAMS, M.D.; BRANDI GALLOWAY; DONNA WRIGHT; CHANATE BUCHANAN; TONETTA BUGGS; TAMARA ERIKSON

Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-02

The Fourth Circuit affirmed the district court’s denial of qualified immunity to supervisory correctional officers Erik Riddell and Jessica Whitaker in a § 1983 action alleging deliberate indifference to the serious medical needs of a pretrial detainee. The court held that, at the time of the alleged violations in June 2019, it was clearly established law under the Fourteenth Amendment’s Due Process Clause that non-medical prison officials could be liable for failing to act when they knew or should have known that a detainee faced a substantial risk of serious harm from inadequate medical care, even if the detainee was receiving some treatment from medical staff. The court applied the qualified immunity standard, which shields officials unless their conduct violates clearly established statutory or constitutional rights. While noting that the Fourth Circuit had recently adopted an objective test for deliberate indifference in *Short v. Hartman* (2023), the court determined this change did not affect the analysis because the right was already clearly established under the prior subjective standard and the core principle remained unchanged: negligence is insufficient, but ignoring indications that initial medical treatment is inadequate constitutes a constitutional violation. The court relied on precedents such as *Cooper v. Dyke*, *Sosebee v. Murphy*, and *Iko v. Shreve* to establish that officials cannot simply defer to medical personnel when confronted with continued complaints, manifest symptoms (such as a grapefruit-sized abscess), or warnings from subordinate officers indicating that the provided care was insufficient. The court found that viewing the facts in the light most favorable to the plaintiff, a reasonable officer would have understood that placing the detainee in solitary confinement without access to medical grievance channels while ignoring repeated reports of her deteriorating condition violated clearly established law. The practical consequence is that the case proceeds to trial on the merits of the deliberate indifference claim against Riddell and Whitaker, as the district court’s finding that genuine disputes of material fact exist regarding their knowledge and actions precludes summary judgment at this stage.

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