Fourth Circuit Revives NC Inmate Claims Over Shackling and Opioid Treatment Denial

The United States Court of Appeals for the Fourth Circuit issued a significant ruling on September 10, 2026, reviving civil rights claims brought by a former North Carolina inmate who alleged she was shackled during childbirth and denied medication for opioid use disorder after giving birth.

Background

Tracey Edwards was incarcerated at the North Carolina Correctional Institution for Women (NCCIW) while pregnant. Because she had been diagnosed with opioid use disorder (OUD), prison medical staff provided her with medication-assisted treatment (MOUD) during her pregnancy, consistent with an internal NCCIW policy.

When Edwards was transported to a hospital for labor and delivery in December 2019, prison officers applied wrist and ankle restraints. Edwards alleged she remained shackled at various stages of labor, delivery, and her return to the facility — despite a prison policy, DAC Policy F.1100, that restricted or prohibited the use of restraints on pregnant inmates.

After she gave birth, NCCIW discontinued her MOUD treatment on the grounds that she was no longer pregnant. Edwards alleged that the abrupt withdrawal of medication caused severe withdrawal symptoms and constituted deliberate indifference to her serious medical needs.

The Fourth Circuit's Ruling

A three-judge panel vacated the district court's grant of summary judgment and remanded the case for further proceedings on multiple claims.

Shackling and the Eighth Amendment

The court held that "shackling a pregnant offender during labor and immediately postpartum poses an objectively serious risk of harm under the Eighth Amendment," absent evidence that the individual presents a security or flight risk. The panel found that because prison officers had been trained on policies explicitly prohibiting such conduct, the wrongfulness of their actions was "obvious," and they were on notice that shackling Edwards could be unconstitutional.

The court revived claims against Warden Benita Witherspoon and four officers, while affirming summary judgment for three other officers whose conduct did not rise to the level of deliberate indifference.

Denial of Opioid Treatment

The Fourth Circuit also held that the district court erred in granting summary judgment to NCCIW medical officials regarding the denial of MOUD after Edwards gave birth. The panel found that a jury could conclude the doctors were deliberately indifferent to a serious medical need by enforcing a blanket policy that categorically denied MOUD to non-pregnant inmates.

The court rejected the argument that providing an oxycodone taper constituted constitutionally adequate care, noting that "providing some care — even if unreasonable or deficient — does not clear the constitutional bar."

Disability Discrimination Claims

Edwards also brought claims under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act, arguing that the denial of MOUD constituted discrimination based on her disability — opioid use disorder. The district court had dismissed these claims by focusing on Edwards' pregnancy rather than her OUD diagnosis.

The Fourth Circuit vacated that dismissal, noting that the lower court had misframed the issue. Because there is "growing recognition that substance abuse and OUD are disabilities," the panel remanded the ADA and Rehabilitation Act claims for proper evaluation.

Significance for North Carolina

The ruling carries particular weight for North Carolina, where NCCIW is located. It signals that categorical policies denying medication-assisted treatment to incarcerated individuals — regardless of pregnancy status — may face constitutional scrutiny. It also reinforces that prison officials cannot ignore their own written policies prohibiting the shackling of pregnant inmates without risking civil liability.

Advocates for incarcerated people have long argued that shackling during labor is both medically dangerous and degrading. The Fourth Circuit's decision, while not a final judgment on the merits, allows Edwards' claims to proceed to trial and may prompt correctional facilities across the circuit — which covers North Carolina, South Carolina, Virginia, Maryland, and West Virginia — to review their restraint and medical treatment policies.

The case, *Edwards v. Witherspoon*, No. 24-7049, was decided by a panel that included Judges King and Wynn in the majority.