The U.S. Court of Appeals for the Eleventh Circuit has affirmed a lower court's dismissal of constitutional claims brought by prisoner James Bailey against prison medical care providers in *Bailey v. Lopez-Rivera* (11th Cir. 2026).
The appeals court upheld two orders from the U.S. District Court for the Northern District of Florida that denied Bailey's motion to amend his complaint and dismissed his Section 1983 claims alleging Eighth Amendment deliberate indifference against multiple defendants including Centurion LLC, Dr. Luis Lopez-Rivera, and the Florida Department of Corrections.
Bailey, serving as plaintiff-appellant, challenged the district court's Rule 12(b)(6) dismissal of his claims against Centurion and Dr. Lopez-Rivera. He argued that he had plausibly alleged sufficient facts to support his claims for relief under the constitutional standard for deliberate indifference to serious medical needs.
The case centers on allegations that the defendants failed to provide adequate medical care in violation of the Eighth Amendment's prohibition against cruel and unusual punishment. Under established precedent, prisoners alleging deliberate indifference must show that prison officials were both objectively aware of a substantial risk of serious harm and subjectively disregarded that risk.
Centurion LLC, a private healthcare company that provides medical services to correctional facilities, was named as a defendant alongside Dr. Lopez-Rivera in the original lawsuit. The Florida Department of Corrections was also included as a defendant in Bailey's claims.
Bailey additionally challenged the district court's denial of his motion to amend the complaint. He argued that his proposed amended complaint was not futile because he had plausibly alleged sufficient facts to support claims against Secretary Ricky Dixon in both his individual and official capacities. The district court's rejection of this motion was also upheld by the Eleventh Circuit.
The appeals court issued a brief per curiam opinion affirming the lower court's decisions without oral argument, indicating the panel found no reversible error in the district court's analysis. The case was heard before Circuit Judges Luck, Lagoa, and Wilson.
Section 1983 lawsuits allow individuals to sue government officials and entities for violations of constitutional rights. These cases are common in the prison context, where inmates frequently challenge conditions of confinement, medical care, and treatment by correctional staff.
Deliberate indifference claims require prisoners to meet a high legal standard. They must demonstrate that prison officials knew of and disregarded an excessive risk to inmate health or safety. Courts distinguish between negligent medical care, which does not violate the Constitution, and deliberate indifference, which does.
The involvement of private healthcare companies like Centurion in correctional medical care has become increasingly common as states and the federal government have contracted out prison healthcare services. These arrangements can create complex liability questions when inmates allege constitutional violations.
Rule 12(b)(6) motions to dismiss test whether a complaint states a plausible claim for relief. Courts must accept all factual allegations as true but need not accept legal conclusions. The standard requires more than mere possibility of wrongdoing but less than probability.
The Eleventh Circuit's affirmance suggests that Bailey's allegations, even taken as true, were insufficient to state viable constitutional claims against the defendants. The court's decision not to elaborate extensively in a published opinion indicates the appeal lacked merit requiring detailed analysis.
Bailey's inability to amend his complaint suggests that additional factual allegations would not have cured the deficiencies the district court identified in his original pleading. Courts deny leave to amend when proposed amendments would be futile or fail to state viable claims.
The case reflects the ongoing challenges prisoners face in successfully pursuing constitutional claims against prison medical providers. Courts require specific factual allegations demonstrating deliberate indifference rather than mere disagreement with medical treatment decisions.
For prison healthcare providers, the decision reinforces existing protections against liability for medical care that may be negligent but does not rise to the level of constitutional violations. The deliberate indifference standard continues to provide a meaningful barrier to frivolous litigation while preserving remedies for genuine constitutional violations.
The Eleventh Circuit's jurisdiction covers Alabama, Florida, and Georgia, making this decision binding precedent for federal courts in those states. The per curiam nature of the opinion and its designation as not for publication limits its precedential value beyond the immediate case.
No further appeals appear likely given the straightforward nature of the court's affirmance and the high standard required for Supreme Court review of circuit court decisions in prisoner civil rights cases.