The United States Court of Appeals for the Fourth Circuit stated in its November 20, 2025 decision: “Starting with Gunter’s § 1983 claim for deliberate indifference under the Fourteenth Amendment, we find that the district court erred in finding Gunter’s evidence did not “create a genuine dispute of material fact” that Medical Appellees “were deliberately indifferent to [Gunter’s] medical needs.” J.A. 1845; Gunter, 2021 WL 4255370 at *31. Gunter, as a pre-trial detainee, need only show that the challenged government action was “not rationally related to a legitimate nonpunitive purpose or [wa]s excessive in relation to that purpose” to establish deliberate indifference. Short v. Hartman, 87 F.4th 593, 611 (4th Cir. 2023), cert. denied, 144 S. Ct. 2631 (2024) (quoting Kingsley v. Hendrickson, 576 U.S. 389, 398 (2015)). While the district court did not have the benefit of this Court’s decision in Short, Short now governs our analysis here.
“The record makes clear that Gunter has presented sufficient evidence to proceed beyond the summary judgment stage, and thus remand is unnecessary. Applying the test articulated in Short, we first ask whether Gunter had an objectively serious medical condition. See id. at 612. Gunter’s heart condition qualifies as objectively serious.
“The next step requires that the plaintiff show “that the defendant acted or failed to act in the face of an unjustifiably high risk of harm that is either known or so obvious that it should be known.” Id. at 611 (quoting Farmer v. Brennan, 511 U.S. 825, 836-37 (1994)). Gunter need not prove that each defendant had “actual knowledge;” as Short clarified, he must show only “that the defendant[s] should have known of that condition and that risk,” and acted objectively unreasonably. Id. Here, the record indicates that several SHP employees, including Jackson and Maldonado, had actual knowledge of Gunter’s condition and medication needs, and that his medical requirements were reflected in Jackson’s medical notes and the faxed medical record Jackson received from a clinic. A reasonable jury could therefore find that the available medical information put Medical Appellees on sufficient notice that depriving Gunter of Coumadin would incite acute health issues. That Gunter subsequently experienced blood clots satisfies the final prong of the Short test, which requires the plaintiff be harmed by the defendant’s action or inaction. Id.
“As we have frequently explained, “no legitimate nonpunitive goal is served by a denial or unreasonable delay in providing medical treatment where the need for such treatment is apparent.” Id. at 606 (citing Martin v. Gentile, 849 F.2d 863, 870 (4th Cir. 1988)). Accordingly, the district court erred by dismissing this claim at the summary judgment stage.”
Source Swink v. Southern Health Partners, Inc., No. 21-2183.
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