Case Citator › Dean Effarage Farrow v. Dr. West

Dean Effarage Farrow v. Dr. West

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Eleventh Circuit
Citation
320 F.3d 1235
Decided
Confirmed treatments
1
Flagged citations read
72 of 72
Treatment dates
2024

Status

Overruled in part
A reviewed court has overruled part of this case’s holding. Dean Effarage Farrow v. Dr. West remains good law on serious medical need and delayed dental treatment, but its “more than mere negligence” formulation of deliberate indifference was displaced by the Eleventh Circuit sitting en banc in Wade v. McDade, listed below. All 72 flagged citations have been read.
More on how this was screened

Stalley v. Lake CI Warden (2024) continued to cite Farrow for serious medical need while explaining that Wade replaced the former negligence formulations with criminal recklessness.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

72 citations to Dean Effarage Farrow v. Dr. West sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Dean Effarage Farrow v. Dr. West?

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Treatments

Overruled in part

  • The en banc Eleventh Circuit replaced the “more than mere negligence” formulation Farrow repeated with a subjective criminal recklessness standard; Farrow's medical need holding survives.

    Wade v. McDade · Eleventh Circuit en banc · filed

    Having reconsidered the issue, we now repudiate our dueling “more than” formulations and hold instead that a deliberate-indifference plaintiff must prove that the defendant acted with “subjective recklessness as used in the criminal law,” Farmer, 511 U.S. at 839
    Read the full opinion on CourtListener →

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