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Burger v. Bloomberg

United States Court of Appeals, Eighth Circuit
Aug 15, 2005
418 F.3d 882 (8th Cir. 2005)

Summary

holding that ADA claims cannot be based on medical treatment decisions

Summary of this case from Henson v. Corizon Health LLC

Opinion

No. 04-3131.

Submitted: August 5, 2005.

Filed: August 15, 2005.

Appeal from the United States District Court for the District of South Dakota, John E. Simko, J.

Stephanie Pochop, Gregory, SD, for appellant.

Melissa C. Hinton and Mark F. Marshall, Sioux Falls, SD, for Appellees Schulte, Regier, and Sioux Valley Hospital Association.

James E. Moore and Cheri S. Raymond, Sioux Falls, SD, for Appellees Jeff Bloomberg, Doug Weber, Bob Dooley, and South Dakota Department of Corrections.

Before BYE, McMILLIAN, and RILEY, Circuit Judges.


Tracy Burger (Burger), as personal representative of Anthony King's (King) estate, appeals the district court's adverse grant of summary judgment. After King died while in the custody of the South Dakota Department of Corrections (DOC), Burger sued the DOC, certain DOC officials, the Sioux Valley Hospital Association, and two medical professionals, claiming violations of section 504 of the Rehabilitation Act (Rehab Act). Burger based her claim on allegations of inadequate medical care for King's diabetes.

The Honorable John E. Simko, United States Magistrate Judge for the District of South Dakota, to whom the case was referred for final disposition by consent of the parties pursuant to 28 U.S.C. § 636(c).

Burger waived her remaining claims on appeal. See Shade v. City of Farmington, Minn., 309 F.3d 1054, 1058 n. 6 (8th Cir. 2002).

Having conducted a de novo review of the record, see Jolly v. Knudsen, 205 F.3d 1094, 1096 (8th Cir. 2000), we agree with two other circuits that have recently concluded a lawsuit under the Rehab Act or the Americans with Disabilities Act (ADA) cannot be based on medical treatment decisions, see, e.g., Schiavo ex rel. Schindler v. Schiavo, 403 F.3d 1289, 1294 (11th Cir. 2005) (Rehab Act, like ADA, was never intended to apply to decisions involving medical treatment); Fitzgerald v. Corr. Corp. of Am., 403 F.3d 1134, 1144 (10th Cir. 2005) (inmate's claims under Rehab Act and ADA were properly dismissed for failure to state claim as they were based on medical treatment decisions). Cf. Monahan v. Nebraska, 687 F.2d 1164, 1170-71 (8th Cir. 1982) ("We do not read § 504 as creating general tort liability for educational malpractice. . . .").

Accordingly, we affirm. See 8th Cir. R. 47B.


Summaries of

Burger v. Bloomberg

United States Court of Appeals, Eighth Circuit
Aug 15, 2005
418 F.3d 882 (8th Cir. 2005)

holding that ADA claims cannot be based on medical treatment decisions

Summary of this case from Henson v. Corizon Health LLC

holding that a [Rehabilitation Act] RA and/or an ADA claim cannot be based on medical treatment decisions

Summary of this case from Williams v. Ferguson

holding that an RA and/or an ADA claim cannot be based on medical treatment decisions

Summary of this case from Bonds v. S. Health Partners, Inc.

holding that an ADA claim cannot be based on medical treatment decisions

Summary of this case from Johnson v. Swibas

holding that claims pursuant to the ADA or the Rehabilitation Act "cannot be based on medical treatment decisions"

Summary of this case from Brown v. Hoops

holding that claims pursuant to the ADA or the Rehabilitation Act "cannot be based on medical treatment decisions"

Summary of this case from Brown v. Hoops

holding that claims pursuant to the ADA or the Rehabilitation Act "cannot be based on medical treatment decisions"

Summary of this case from Watson v. Sisto

holding that ADA claims cannot be based on medical treatment decisions

Summary of this case from Mascetti v. Zozulin

concluding that a lawsuit under the ADA "cannot be based on medical treatment decisions"

Summary of this case from Wenzke v. Munoz

concluding that a lawsuit under the ADA "cannot be based on medical treatment decisions"

Summary of this case from Wenzke v. Munoz

concluding that a lawsuit under the ADA "cannot be based on medical treatment decisions"

Summary of this case from Frazier v. Bonds

concluding that a lawsuit under the ADA "cannot be based on medical treatment decisions"

Summary of this case from Webster v. New Jersey

concluding that a lawsuit under the ADA "cannot be based on medical treatment decisions"

Summary of this case from Owens v. Rutgers Univ. Behavioral Health Care

concluding that a lawsuit under the ADA "cannot be based on medical treatment decisions"

Summary of this case from McClintic v. Pa. Dep't of Corr.

agreeing with the Eleventh and Tenth Circuits in concluding that "a lawsuit under the Rehab Act or the Americans with Disabilities Act (ADA) cannot be based on medical treatment decisions"

Summary of this case from Deweese v. Munyan

agreeing with Schiavo ex rel. Schindler v. Schiavo, 403 F.3d 1289, 1294 (11th Cir. 2005) and Fitzgerald v. Corr. Corp. of Am., 403 F.3d 1134, 1144 (10th Cir. 2005) that ADA claims cannot be based on medical-treatment decisions

Summary of this case from Ligons v. Minn. Dep't of Corr.

In Burger v. Bloomberg, 418 F.3d 882 (8th Cir. 2005), the plaintiff claimed that the South Dakota Department of Corrections, a hospital association, and two medical professionals violated the Rehabilitation Act by providing inadequate medical care for a decedent's diabetes.

Summary of this case from Estate of Smith v. Forest Manor, Inc.

noting that lawsuits under the Rehabilitation Act or ADA "cannot be based on medical treatment decisions"

Summary of this case from Loeber v. Department of Corrections
Case details for

Burger v. Bloomberg

Case Details

Full title:Tracy BURGER, as Personal Representative of the Estate of Anthony King…

Court:United States Court of Appeals, Eighth Circuit

Date published: Aug 15, 2005

Citations

418 F.3d 882 (8th Cir. 2005)

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Within the Eighth Circuit, however, claims under the ADA "cannot be based on medical treatment decisions."…

Nachtweih v. Mo. Dep't of Corrs.

5] at 15 (citing Burger v. Bloomberg, 418 F.3d 882, 883 (8th Cir. 2005) (per curiam)) (“[W]e agree with…