WILMINGTON, DE – A federal judge has ruled in favor of two Delaware prison medical administrators in a lawsuit brought by a former inmate who claimed delays in treatment for a shoulder injury violated his constitutional rights.
Emmanuel Tyree Holliday, who was incarcerated at the Howard R. Young Correctional Institution, filed the lawsuit in 2021 under 42 U.S.C. § 1983, accusing Christine Claudio and Christine Onofrio of failing to provide timely medical care. Holliday, who filed the case without an attorney, alleged that he experienced severe delays in receiving treatment for a left shoulder injury that he says began before his incarceration.
The court reviewed the claims in connection with a motion for summary judgment filed by the defendants and determined that, based on the evidence, no constitutional violation could be established against Claudio or Onofrio.
Claudio served as a Health Services Administrator, and Onofrio worked as a Consult Coordinator—both in largely administrative roles for Centurion of Delaware, the prison’s contracted medical provider during the time in question. According to court documents, neither defendant was directly involved in providing medical care to Holliday, but instead handled scheduling, administrative approvals, and external referrals for inmate treatment.
The case focused on procedural delays Holliday experienced in obtaining specialist evaluation and treatment, which he claimed caused unnecessary pain. Medical records indicate that although Holliday reported pain upon intake in 2020, he did not submit formal requests for shoulder-related medical attention until months later.
The court found that both Claudio and Onofrio acted within the scope of their duties and had no direct control over the pace of medical approvals or clinical decisions, which were handled by licensed prison medical providers and the Utilization Management process.
In addition to seeking damages, Holliday had requested injunctive relief, asking the court to intervene in the prison’s medical practices. However, with Holliday no longer incarcerated and no active harm alleged, the court found no grounds for such relief.
Judge Colm F. Connolly issued the decision from the bench in Wilmington on Thursday, effectively ending the claims against Claudio and Onofrio. Holliday’s separate request for court-appointed legal representation was also denied.