Reasonable Reliance on Jail Medical Staff Shields Nonmedical Officers from Deliberate Indifference Liability: Commentary on Tiffany Wingo v. Major Branson Harris

I. Introduction

The Eleventh Circuit’s decision in Tiffany Wingo v. Major Branson Harris squarely addresses a recurrent and difficult question in jail and prison litigation: when, if ever, can nonmedical correctional officers be held constitutionally liable for an inmate’s medical harm after they have deferred to medical staff?

In this published opinion, the court:

Announces a clear rule that a nonmedical jail officer cannot be found liable for deliberate indifference under the Fourteenth Amendment when the officer reasonably relies on the advice or opinion of a medical professional, and
Confirms that, where causation turns on complex medical questions, a plaintiff must offer competent expert testimony that connects the alleged negligence to the specific time period and defendant at issue; general statements that “earlier treatment is better” are not enough.

The case arises from the tragic death of pretrial detainee Kevil Wingo at the Cobb County Adult Detention Center after nurses misdiagnosed a perforated gastric ulcer as drug withdrawal (“detox”). The opinion is legally significant because it:

Solidifies, in the Eleventh Circuit, a “reasonable reliance on medical staff” safe harbor for nonmedical officers under 42 U.S.C. § 1983, aligned with multiple sister circuits; and
Clarifies the stringent requirements of medical causation proof for both federal deliberate indifference claims and Georgia state-law negligence claims against a specific officer whose involvement was limited in time.

II. Factual and Procedural Background

A. The Underlying Events

In September 2019, Kevil Wingo was arrested in Cobb County, Georgia, for possessing 0.2 grams of cocaine and booked as a pretrial detainee at the Cobb County Adult Detention Center.

A few days into his detention, Wingo began to complain of:

Abdominal pain
Nausea and vomiting
Profuse sweating

Deputy Quinton Appleby took him to the facility’s infirmary. On the way, Wingo told Appleby he had an ulcer; Appleby relayed that information to the nursing staff.

At approximately 12:35 a.m., Nurse Yvette Burton (employed via WellStar Health Systems) admitted Wingo to the infirmary. The operational structure in the infirmary is critical:

Medical staff (WellStar nurses) controlled diagnosis, treatment, and medical decisions.
Sheriff’s deputies were present for security and deliberately trained not to make medical decisions, but to defer to the medical staff.

On admission, Wingo:

Complained of nausea, vomiting, abdominal discomfort
Was heard pleading with God and vowing never to use drugs again if he survived

He was in the midst of a mandatory five-day “withdrawal check” protocol for opiates. Based on his symptoms, his withdrawal-check status, and her experience that up to 40% of infirmary inmates are detoxing, Nurse Burton diagnosed Wingo as undergoing drug withdrawal. Vitals were taken, and according to another nurse, he was admitted “so he could stay overnight … [and] see the doctor in the morning.”

B. The Deputies’ Interactions with Wingo

1. Deputy McPhee (overnight)

Deputy Britton McPhee, assigned to the infirmary, monitored Wingo overnight.
Wingo was “very loud,” disruptive, and repeatedly requested to be taken to the hospital.
Following his training, McPhee told Wingo that hospital decisions belonged to the medical staff, prompting Wingo to tell him to “just shut … up and do what I’m telling you to do.”

2. Deputy Marshall (early morning)

At 6:00 a.m., Deputy Lynda Marshall (a 27+ year veteran) relieved McPhee. McPhee told her:

Wingo had been “hollering” and disruptive all night, demanding hospital care; and
The nurses said Wingo was detoxing.

With long experience seeing detoxing inmates, Marshall found Wingo’s symptoms consistent with withdrawal and agreed with the nurses’ assessment.

Nurse Annaleen Visser, who replaced Burton on the day shift, also concluded Wingo was detoxing. She:

Did not conduct a physical assessment because Wingo was not “calm,” and she chose to wait per detox protocols.
Believed that detoxing inmates commonly ask to go to the hospital for better conditions, drugs, and privacy, saying they will “do anything to go to the ER.”

During the early morning hours:

Wingo continued yelling that he needed a hospital and said he could not breathe.
Marshall responded that if he could talk, he was breathing, but she also asked follow-up questions.
She relayed his complaints to the nurses, who insisted Wingo was “just trying to go to the hospital,” was detoxing, drug-seeking, and “okay.”

By this point, other inmates were frustrated and allegedly planned to fight Wingo. Marshall:

Removed Wingo from the cell to prevent potential harm.
When she opened the cell, Wingo fell to the floor, again begging to go to the hospital.
Reported this to the nurses, who did nothing.
Called her supervisor, Lieutenant Charles Gordon, for direction.

3. Lieutenant Gordon and Major Harris (7:30–7:45 a.m.)

At about 7:30 a.m., Lt. Gordon arrived. He:

Saw Wingo on the ground.
Was told by Marshall that Wingo had been causing issues with other inmates.
Asked Nurse Visser if Wingo was “okay”; she responded he was “medically fine.”
Advised Marshall to call his superior, Major Branson Harris.

When Major Harris arrived:

Nurse Visser reiterated that Wingo was detoxing and drug seeking.
She recommended that Wingo be placed in a padded isolation cell due to behavioral issues, but the only single cell in the infirmary was occupied.
She proposed transfer to a padded cell in the infirmary extension, where he could be under close observation.
Harris asked whether such a transfer was medically appropriate; Visser confirmed it was.

At about 7:45 a.m., Harris and Gordon:

Escorted Wingo to the extension.
Determined he was too unstable to walk and used a wheelchair.
Again asked the nurses why Wingo was unbalanced and were told it was a detox symptom.
Left him in a padded cell in the extension.

4. Deputy Wilkerson (7:45–8:49 a.m.)

Deputy Paul Wilkerson, assigned to the infirmary, became responsible for monitoring Wingo in the extension. Jail policy required:

Security rounds every 12 minutes for detainees under close observation; and
Visual checks by looking into each cell, not just relying on camera feeds.

Wilkerson:

Admitted he did not look directly into Wingo’s cell on every round.
Relied in part on the camera feed, where he saw Wingo change position a few times and believed he was still alive and well.
At 8:22 a.m., did a joint security check with Major Harris; both believed they saw Wingo’s chest rising and falling.

However, at 8:49 a.m., when Wilkerson opened the cell:

Wingo was motionless; initially Wilkerson thought Wingo might be “playing a game” and about to jump up.
He quickly realized Wingo was unresponsive and called the medical team on an emergency basis.
Shortly thereafter, Wingo was declared dead.

An autopsy determined that Wingo died from complications of a perforated gastric ulcer with peritonitis.

C. Litigation and District Court Rulings

Wingo’s daughter, Tiffany Wingo, acting as administrator of his estate and joined by other surviving children and representatives, sued. The claims relevant on appeal included:

§ 1983 deliberate indifference claims against Major Harris, Lt. Gordon, Deputy Marshall, and Deputy Wilkerson (and others initially) for alleged violation of Wingo’s Fourteenth Amendment rights.
Georgia state-law negligence claim against Deputy Wilkerson for failing to perform required security rounds and checks.

Medical provider WellStar and its nurses settled and were dismissed. The sheriff’s deputies remained as defendants.

Plaintiffs’ causation case relied on expert Dr. Brian Myers, who opined that the defendants’ inaction caused Wingo’s death. Critically, however, Dr. Myers testified that:

The chances of survival from a ruptured ulcer decrease over time.
But he could not say “with any degree of medical certainty” whether Wingo could have been saved at 7:45 a.m.—the time Wingo came under Wilkerson’s watch in the extension.
His causation opinion “doesn’t bring into the issue of time,” and he could not opine whether at 7:45 Wingo would have survived with different treatment.

The district court:

Granted summary judgment on all § 1983 claims, invoking qualified immunity and concluding that the deputies were not deliberately indifferent in light of their reliance on medical staff.
Granted summary judgment to Deputy Wilkerson on the state negligence claim, finding that Dr. Myers’s testimony did not establish causation with the necessary medical certainty as to the 7:45–8:49 a.m. period.

The plaintiffs appealed as to the deputies.

III. Summary of the Eleventh Circuit’s Opinion

The Eleventh Circuit (Judge Brasher, joined by Judges Rosenbaum and Grant) affirmed across the board, issuing a published opinion with two central holdings:

Deliberate Indifference / Reasonable Reliance Rule
The court held that a nonmedical jail officer cannot be held liable for deliberate indifference when he or she reasonably relies on the advice or opinion of a medical professional. Because Deputies Marshall, Gordon, and Harris relied on repeated assurances from nurses that Wingo was detoxing, medically stable, and “fine,” they did not act with the subjective recklessness required for a Fourteenth Amendment deliberate indifference claim.
Causation as to Deputy Wilkerson
The court held that even assuming Dr. Myers’s testimony were admissible, it failed to create a genuine issue of material fact on causation regarding Wilkerson. The expert’s inability to say, with any degree of medical certainty, whether treatment after 7:45 a.m. would have saved Wingo meant no reasonable jury could find that Wilkerson’s conduct caused Wingo’s death under either § 1983 or Georgia negligence law.

The court therefore affirmed the grant of summary judgment in favor of all deputy defendants.

IV. Detailed Analysis

A. The Deliberate Indifference Framework

The court situates its analysis within the now-settled Eleventh Circuit deliberate indifference standard, citing its recent en banc decision in Wade v. McDade, 106 F.4th 1251 (11th Cir. 2024).

Under Wade (and Farmer v. Brennan, 511 U.S. 825 (1994)), a plaintiff must prove:

Objective component: The detainee suffered a deprivation that was “sufficiently serious” (a “serious medical need”).
Subjective component: The defendant acted with “subjective recklessness as used in the criminal law”—i.e., was actually, subjectively aware that his own conduct created a substantial risk of serious harm and disregarded that risk.

The court quotes Wade for the proposition that the plaintiff must show the “defendant was actually, subjectively aware that his own conduct caused a substantial risk of serious harm.”

Here, there is little dispute that a perforated gastric ulcer is a “serious medical need.” The litigation focused on the subjective awareness / reckless disregard element: did the deputies know that their own failure to act (e.g., not sending Wingo to the hospital, not insisting on further medical review) was exposing him to a substantial risk of serious harm?

B. The “Reasonable Reliance on Medical Staff” Safe Harbor

1. The Court’s Express Holding

The court’s key doctrinal contribution appears early and is framed as a clear holding:

“We hold that a nonmedical jail officer cannot be found liable for deliberate indifference when he or she reasonably relies on the advice or opinion of a medical professional.”

This statement transforms what had been implicit or case-specific reasoning into a more explicit, generally applicable rule: if the officer’s reliance on medical staff is reasonable, that officer does not meet the subjective recklessness standard for deliberate indifference.

2. Precedents Cited and Their Influence

The opinion grounds this rule in both Eleventh Circuit and sister-circuit authority.

a. Eleventh Circuit: Townsend v. Jefferson County

In Townsend v. Jefferson County, 601 F.3d 1152 (11th Cir. 2010), the court held that correctional officers who relied on a nurse’s professional judgment that a situation was “not an emergency” were not deliberately indifferent. There, as here:

Nonmedical officers observed concerning symptoms.
The officers sought input from medical staff.
Medical professionals downplayed the severity.
The court refused to second-guess the officers’ reliance on those medical judgments absent evidence of obvious, gross misjudgment apparent even to a layperson.

The Wingo opinion explicitly analogizes to Townsend, and also adopts its implicit limitation:

“Townsend has not presented evidence that her situation was so obviously dire that two lay deputies must have known that a medical professional had grossly misjudged Townsend’s condition.”

Wingo assumes, “without deciding,” that nonmedical officers may not reasonably rely on medical opinions that are “obviously wrong even to a layman.” This is a crucial caveat: the safe harbor is conditioned on reasonableness, not blind deference.

b. Sister Circuits: Cross-Circuit Consensus

The panel emphasizes that its approach aligns with other circuits, suggesting this rule is now part of a national consensus:

Eighth Circuit – Smith v. Lisenbe, 73 F.4th 596 (8th Cir. 2023): A prison official may rely on a medical professional’s opinion if that reliance is reasonable.
Tenth Circuit – Estate of Beauford v. Mesa County, 35 F.4th 1248 (10th Cir. 2022): Prison officials may generally rely on advice and treatment prescribed by medical personnel.
Seventh Circuit – Giles v. Godinez, 914 F.3d 1040 (7th Cir. 2019): Recognizes long-standing principle that nonmedical officials may reasonably defer to medical professionals’ judgment on inmate treatment.
Sixth Circuit – Winkler v. Madison County, 893 F.3d 877 (6th Cir. 2018), and Third Circuit – Spruill v. Gillis, 372 F.3d 218 (3d Cir. 2004) adopt similar views.

By cataloging these authorities, the court signals that it is not innovating in isolation but expressly aligning the Eleventh Circuit with a broad judicial consensus: nonmedical officers are entitled—indeed expected—to defer to medical professionals in clinical matters, so long as the deference is reasonable under the circumstances.

3. Application to the Deputies’ Conduct

The court carefully matches the new rule to the factual record.

Deputy Marshall received repeated assurances from nurses that Wingo was detoxing, drug-seeking, and “okay,” even after reporting that he was yelling, complaining he could not breathe, and demanding hospital care. Her own experience with detoxing inmates made the nurses’ diagnosis plausible.
Lieutenant Gordon personally asked Nurse Visser if Wingo was “okay” and was told he was “fine medically.” When Wingo was too unsteady to walk, the nurses attributed that, again, to detoxing.
Major Harris asked Visser whether it was medically appropriate to move Wingo to a padded cell in the extension; she assured him it was and repeated the detox/drug-seeking diagnosis.

On these facts, the court holds that the deputies’ deference to medical staff was not only permissible but reasonable:

The medical staff had already taken vitals and made an initial assessment.
The nurses were repeatedly apprised of Wingo’s ongoing complaints and new symptoms.
At each point, the nurses affirmed that Wingo was stable and in detox; they did not order hospital transfer.

Critically, the court underscores that a perforated ulcer is not a condition obvious to laypersons:

“A perforated ulcer is hidden in the body and presents diffuse symptoms like nausea, vomiting, and abdominal discomfort. It is not the kind of ailment that a layman can easily diagnose.”

Thus, even though Wingo’s condition was in fact dire, the deputies lacked the medical expertise to recognize the misdiagnosis, and they repeatedly sought and relied upon medical guidance.

4. Addressing Plaintiff’s Counter-Arguments

The plaintiffs advanced two major counter-arguments, which the court rejects.

a. “Obvious Wrongness” Exception

Plaintiffs contended that nonmedical officers cannot rely on medical opinions when those opinions are so wrong that a layperson would recognize the error. The court:

Assumes this proposition is law (“without deciding”), consistent with Townsend’s logic.
Holds that the facts here do not satisfy that exception because the misdiagnosed condition (a perforated ulcer) is internal, medically complex, and symptomatically overlapping with detox.

Because the seriousness of Wingo’s condition was not “so obviously dire” that a lay deputy must have known the nurses were grossly mistaken, the “obvious wrongness” limitation does not displace the reasonable reliance rule.

b. Failure to Seek Re-Examination After Wingo Began to Stumble

Plaintiffs also argued that once Wingo exhibited new symptoms (e.g., stumbling, falling when the cell door opened), the deputies could no longer reasonably rely on the earlier detox diagnosis without demanding renewed medical evaluation.

The court responds that:

The nurses had already taken vitals and placed Wingo under observation.
As symptoms evolved, the deputies continued to communicate with the nurses.
Each time, the nurses reaffirmed that Wingo was stable and exhibiting expected detox symptoms.
The nursing staff expressly attributed Wingo’s unsteadiness to withdrawal and still did not consider his condition life-threatening.

Therefore, from the deputies’ perspective, the situation remained within the scope of the nurses’ considered (though ultimately mistaken) medical judgment. There was no clear, lay-obvious basis to override or disregard that judgment.

5. Limits and Implications of the Safe Harbor

Although the opinion strongly protects nonmedical officers who reasonably defer to medical staff, it is not an absolute shield. Key limitations include:

Reliance must be reasonable in light of what the officer knows and observes.
Clearly obvious emergencies (e.g., visible traumatic injuries, unconsciousness, seizures, or respiratory arrest ignored by medical staff) may still support liability if a lay officer should recognize the need to act despite medical assurances.
Officers cannot deliberately withhold information from medical staff or fail to communicate new, critical changes in condition and then hide behind medical opinions issued on incomplete facts.

Wingo sets a default rule: where medical professionals are informed, engaged, and repeatedly insist the detainee is medically stable, nonmedical officers will almost always be protected from deliberate indifference liability for following that judgment.

C. Causation and Expert Testimony: Claims Against Deputy Wilkerson

1. Causation Requirements in § 1983 and Georgia Negligence Law

The court emphasizes that both:

Federal deliberate indifference claims under § 1983, and
Georgia state-law negligence claims

require proof of causation.

Federal law (deliberate indifference): Citing Marbury v. Warden, 936 F.3d 1227 (11th Cir. 2019), the court notes that a successful deliberate indifference claim requires proof that the defendant’s conduct caused the plaintiff’s injury.
Georgia law (negligence): Citing Collins v. Athens Orthopedic Clinic, P.A., 837 S.E.2d 310 (Ga. 2019), the court recites the familiar elements: duty, breach, causation, and damages.

When causation involves complex medical questions—such as whether a particular delay in care at a particular time would have changed the outcome—expert testimony is required. The opinion cites:

Alberson v. Norris, 458 F.3d 762 (8th Cir. 2006) and Barnes v. Anderson, 202 F.3d 150 (2d Cir. 1999) for § 1983 claims, and
Cowart v. Widener, 697 S.E.2d 779 (Ga. 2010) and Fed. R. Evid. 702 for state medical/negligence claims.

The rationale is straightforward: unless laypeople can obviously see that the alleged negligence caused the harm, medical experts must bridge the gap.

2. Dr. Myers’s Testimony and Its Limitations

As to Deputy Wilkerson specifically, Dr. Myers testified that:

The probability of survival from a ruptured ulcer declines with time (i.e., earlier intervention generally improves outcomes).
However, he could not say “with any degree of medical certainty” whether Wingo would have survived if treated when he came under Wilkerson’s observation at 7:45 a.m.
His causation opinion did “not bring into the issue of time”; he could not opine on survival probability at that specific time point.

The district court reasoned that, even assuming the expert’s testimony was admissible, this temporal gap meant the plaintiffs could not show that Wilkerson’s failure to call for help between 7:45 and 8:49 a.m. more likely than not caused Wingo’s death.

The Eleventh Circuit agrees:

“Although Dr. Myers’s testimony may have allowed a reasonable jury to find the nurses or other guards liable for their conduct earlier in the night, no reasonable jury could find Deputy Wilkerson liable based on this testimony.”

In other words:

There might be evidence that substantial delay before 7:45 a.m. was causally significant.
But the plaintiffs failed to provide expert proof that additional delay between 7:45 and 8:49 a.m.—the only period attributable to Wilkerson—altered Wingo’s outcome to a reasonable degree of medical probability.

Without that, causation is speculative as to Wilkerson, and both § 1983 and negligence claims fail at summary judgment.

3. Interaction with Summary Judgment Standards

Under Fed. R. Civ. P. 56(a), summary judgment is appropriate where no genuine dispute of material fact exists and the movant is entitled to judgment as a matter of law. A fact issue is “genuine” only if a reasonable jury could return a verdict for the nonmovant, given the evidence.

Here:

There is no non-expert evidence that could allow lay jurors to conclude that the final roughly one hour of custodial care made a difference between life and death in a perforated ulcer case.
Dr. Myers expressly declined to state such a conclusion with any degree of medical certainty.

Consequently, there was no triable issue of causation as to Wilkerson, and summary judgment was proper.

D. Qualified Immunity in the Background

The district court granted summary judgment on the § 1983 claims largely on qualified immunity grounds. The Eleventh Circuit, however, focuses on and resolves the appeal on the underlying constitutional merits:

By holding that the deputies did not act with deliberate indifference (given reasonable reliance), the court effectively concludes that no constitutional violation occurred.
Once there is no constitutional violation, qualified immunity is unnecessary as an alternative holding; but the district court’s qualified immunity reasoning is consistent with the panel’s merits analysis.

Practically, Wingo strengthens both:

The merits defense (no deliberate indifference where reasonable reliance exists), and
The qualified immunity defense (officers act reasonably—and thus are entitled to immunity—when deferring to trained medical providers absent obvious red flags).

V. Impact and Broader Implications

A. Operational Implications for Jails and Prisons

The opinion reinforces a clear division of labor inside correctional facilities:

Medical professionals diagnose and treat.
Nonmedical officers provide security and relay observations but are not expected to override clinical judgments.

Practically, jail administrators can:

Train officers to promptly report all observable symptoms to medical staff.
Emphasize that once medical staff are fully informed and have given an opinion, officers may rely on that opinion—unless the situation is so obviously dire that it would be unreasonable to do so.
Emphasize documentation: that officers reported symptoms, sought medical input, and followed clinical directions.

This decision also underscores the importance of:

Ensuring adequate medical staffing, training, and oversight in jails; and
Recognizing that constitutional liability for medical misjudgments will often fall, if at all, on the medical providers rather than security staff.

B. Litigation Strategy in § 1983 Medical-Care Cases

For plaintiffs:

Claims against nonmedical officers will be significantly harder to sustain where:
- Officers have consistently referred complaints to medical staff; and
- Medical staff have documented or testified that they assessed the detainee and found no emergency.
Plaintiffs must look for evidence that:
- Officers failed to communicate critical information to medical staff;
- Medical staff never actually assessed the detainee despite clear emergencies; or
- The detainee’s condition became so plainly emergent that a reasonable lay officer would have known that reliance on prior medical assurances was no longer reasonable.

For defendants:

Wingo provides a strong doctrinal basis to move for summary judgment whenever:
- Medical staff were engaged and gave opinions; and
- Officers’ actions were consistent with those opinions.
Officers should carefully document:
- All communications with medical staff;
- Requests for evaluation; and
- Medical staff’s responses and instructions.

C. Re-Channeling Liability Toward Medical Providers and Policy-Level Claims

The reasonable reliance rule inevitably shifts much of the focus in medical-care litigation:

From individual nonmedical officers to:
- Medical personnel (nurses and doctors), and
- Municipal and corporate entities (counties, private health contractors) under theories of policy, custom, or failure to train.

While WellStar and its nurses settled in this case, future plaintiffs may increasingly pursue:

Direct claims against medical providers for deliberate indifference or malpractice; and
Monell-type claims against municipalities or private medical contractors, alleging systemic deficiencies: understaffing, inadequate protocols for differentiating detox from serious internal conditions, or policy-driven misdiagnoses.

D. Expert Testimony and Time-Specific Causation

On the causation front, Wingo sends a clear warning to plaintiffs’ experts: generic statements about “earlier treatment improves outcomes” are not sufficient to sustain liability against a particular defendant who acted only during a specific time window.

Experts must:

Address timing explicitly—e.g., “more likely than not, if treatment had begun by [time], the patient would have survived.”
Differentiate among defendants whose involvement occurred at different stages.
Be prepared to testify, to a reasonable degree of medical certainty, about which delays mattered and which did not.

Otherwise, courts may grant summary judgment for late-in-the-chain actors like Wilkerson, even if earlier misconduct could be causally significant.

VI. Complex Concepts Simplified

1. Deliberate Indifference

“Deliberate indifference” is more than mere negligence or even gross negligence:

The defendant must know of a substantial risk of serious harm and deliberately ignore it.
It is akin to criminal recklessness—the official actually understands the risk and chooses not to respond reasonably.

2. Serious Medical Need

A “serious medical need” exists when:

A doctor says treatment is necessary, or
It is obvious that a layperson would recognize the need for medical attention, or
Untreated, the condition risks significant injury or unnecessary and wanton infliction of pain.

A perforated ulcer with peritonitis plainly qualifies, though it may not be immediately recognizable by lay observers.

3. Subjective Recklessness

This refers to the officer’s mental state:

The officer must actually know of the serious risk created by his conduct.
It is not enough that the officer should have known in some objective sense; there must be evidence of subjective awareness and disregard.

4. Reasonable Reliance on Medical Professionals

This doctrine means:

Nonmedical officers may defer to the professional judgment of medical staff about diagnosis and treatment.
The reliance must be reasonable:
- Officers must have communicated relevant symptoms.
- There must be no obvious contradiction between medical assurances and what a layperson sees.

If those conditions are met, officers are generally not deliberately indifferent simply because the medical staff turned out to be wrong.

5. Summary Judgment

Summary judgment is a procedure where the court decides a case (or an issue) without trial when:

There is no genuine dispute about important facts; and
Based on those undisputed facts, the moving party is entitled to judgment as a matter of law.

The court views the evidence in the light most favorable to the nonmoving party (here, the plaintiffs), but cannot allow a case to go to trial on speculation or conjecture.

6. Qualified Immunity

Qualified immunity shields government officials from liability for civil damages unless:

They violated a constitutional right, and
That right was “clearly established” at the time of the conduct.

In practice, if officers acted in a way that a reasonable officer could believe was lawful—such as following medical advice from jail nurses—they are often entitled to qualified immunity. Wingo reinforces that such deference is reasonable.

7. Causation and “Degree of Medical Certainty”

In medically complex cases:

Experts typically must express opinions in terms of a “reasonable degree of medical certainty” or probability (which generally means “more likely than not”).
If an expert cannot say, even in probability terms, that a particular delay or act caused the outcome, a jury usually cannot reasonably find causation for that defendant.

Because Dr. Myers could not say whether treatment at or after 7:45 a.m. would have saved Wingo, he could not support causation against Wilkerson.

VII. Conclusion

Tiffany Wingo v. Major Branson Harris is a significant Eleventh Circuit decision at the intersection of constitutional law, correctional practice, and medical causation.

Substantively, the case:

Clarifies and strengthens a “reasonable reliance on medical staff” safe harbor for nonmedical officers facing § 1983 deliberate indifference claims.
Aligns the Eleventh Circuit with a robust cross-circuit consensus that nonmedical officers may generally defer to medical professionals on questions of diagnosis and treatment.
Reinforces strict causation requirements for both federal and state claims where causation is medically complex, insisting on time-specific, probability-based expert testimony.

Going forward, the decision will:

Make it more difficult to impose individual constitutional liability on nonmedical jail officers who follow medical advice, absent glaringly obvious emergencies.
Push litigants to focus on the conduct of medical staff, institutional policies, and systemic failures rather than solely on security personnel.
Require more careful, time-sensitive expert causation analysis in detainee medical-death cases, particularly where different actors become involved at different stages.

At a broader level, Wingo underscores a core constitutional principle: while the state must provide minimally adequate medical care to incarcerated persons, constitutional liability under the Fourteenth Amendment turns on subjective recklessness and causation, not on hindsight disagreement with medical judgment. Nonmedical officers who reasonably rely on trained medical professionals, as the deputies did here, will not ordinarily be held deliberately indifferent under § 1983.