From the Courts: Infection; Gender Dysphoria; Solitary Confinement
Author: Ken Kozlowski.
Source: Volume 27, Number 01, Spring 2026 , pp.31-34(4)

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Abstract:
Our regular review of appellate rulings includes three cases: In Moye v. Fountain Correctional Facility, the Eleventh Circuit affirmed a jury verdict finding deliberate indifference where a prison medical director failed to adjust treatment for a worsening infection, leading to an inmate’s partial foot amputation; in Clark v. Valletta, the Second Circuit held that prison officials were entitled to qualified immunity because no clearly established right exists to specific gender-dysphoria treatments or specialist care; and in Sanders v. Moss, the Seventh Circuit affirmed summary judgment for defendants, concluding that prolonged segregation and mental health treatment did not constitute deliberate indifference where the record showed ongoing care and insufficient evidence of unconstitutional conduct.Keywords: Deliberate Indifference; Qualified Immunity; Infection; Gender Dysphoria; Solitary Confinement
Affiliations:
1: Legal Editor.