Qualified Immunity Denied for Iowa Prison Doctor’s MRI Delay for Non-Medical Reasons
The U.S. Court of Appeals for the Eighth Circuit affirmed the denial of qualified immunity to a prison doctor who delayed the scheduling of a prisoner’s MRI due to the prisoner’s upcoming parole hearing and the possibility of a grant of parole.
Iowa prisoner Travis Dantzler sued Dr. Tonia Baldwin, a physician at the Clarinda Correctional Facility (CCF), for deliberate indifference to his complaints of knee pain. Dantzler first injured his knee at Anamosa State Penitentiary in February 17, 2020, while playing basketball. He was prescribed ibuprofen and given a knee sleeve, and a doctor later diagnosed a knee sprain.
Dantzler reinjured the knee on July 6, 2020, while playing basketball. This time, he reported feeling “a pop” in the knee. He was ordered to rest, ice the knee, use a non-steroidal anti-inflammatory cream, rehabilitation, and no sports. Dantzler reported severe pain to medical officials on December 27, 2020, and requested an MRI. The previous plan of care was reordered with advice to use the knee brace.
Dantzler was transferred to CCF on January 6, 2021, and was seen two days later by Baldwin. At that visit and at a January 22 exam, Baldwin noted swelling of the knee with improvement on the second visit. Once again on February 28, 2021, Dantzler reinjured the knee, stating his knee “made a popping noise” while he was “walking laps.”
Between March and September 2021, Dantzler was prescribed ibuprofen and a knee brace to treat the injured knee. Dantzler requested an MRI. Baldwin noted on several occasions that if Dantzler was denied parole, a referral would be required. Three levels of the administrative grievance procedure resulted in approvals of Baldwin’s decision to delay an MRI until a parole decision was rendered. After Dantzler was denied parole, he received an MRI and “a right knee arthroscopy, meniscal repair versus debridement and microfracture.” The delay caused a torn meniscus, and subsequent surgery, to Dantzler’s left knee. He also developed hip pain.
Dantzler’s civil rights action alleged several claims that were narrowed to the claim against Baldwin for delayed treatment of the right knee. Baldwin moved for summary judgment on qualified immunity grounds. The district court denied the motion, and Baldwin filed an interlocutory appeal.
The Eighth Circuit found Dantzler presented a serious medical need. The court found the it was “not clear” that Baldwin’s decision to delay the MRI was a “medical-judgment decision,” for the evidence could establish that she withheld the MRI based on the possibility of Dantzler’s parole rather than for some medical reason.
The Court found that it was clearly established that delaying medical care for a nonmedical reason violates the Eighth Amendment. See: Fisherman v. Launderville, 100 F.4th 978 (8th Cir. 2024). Therefore, Baldwin’s delay of the MRI based upon Dantzler’s possibility of parole could support a finding of deliberate indifference. The district court’s order was affirmed. See: Dantzler v. Baldwin, 133 F.4th 833 (8th Cir. 2025).
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Related legal case
Dantzler v. Baldwin
| Year | 2025 |
|---|---|
| Cite | 133 F.4th 833 (8th Cir. 2025) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
| Appeals Court Edition | F.4th |