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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT TALLAHASSEE DIVISION

CASE NO: 4:20-cv-00513-WS-MJF

THERESA CINEUS as

PERSONAL REPRESENTATIVE OF THE 

ESTATE OF GAMALIEL CINEUS

Plaintiff,

v.

STATE OF FLORIDA, DEPARTMENT OF 

CORRECTIONS, CENTURION OF 

FLORIDA LLC.

Defendant(s), 

___________________________________________/

AMENDED COMPLAINT AND DEMAND FOR A JURY TRIAL

I. INTRODUCTION 

This is an action brought pursuant to the Common Law of the state of Florida, 

Chapter 768.28 of the Florida Statutes, The Eighth Amendment to the US 

Constitution and 42 U.S.C. §1983 and §1988 pursuant to Florida Department of 

Corrections Negligent Supervision of the Centurion medical staff and the 

Deliberate Indifference that Defendant Centurion exhibited toward the medical 

needs of the deceased, Gamaliel Cineus.

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II. JURISDICTION 

1. The jurisdiction of this court is predicated upon 42 USC §1983; §1988 and 28 USC 

1331.

III. PARTIES 

2. The Plaintiff in this case is Theresa Cineus who has brought this action in her 

official capacity as the Personal Representative of her deceased son, Gamaliel 

Cineus’ estate.

3. The State of Florida is a Defendant in this matter because events complained about 

herein occurred inside a Florida Department of Corrections facility.

4. The Defendant, Centurion of Florida LLC, hereafter referred to as the private 

medical contractor, provided medical services to inmates confined to the Florida 

Department of Corrections.

IV. FACTUAL ALLEGATIONS 

5. The Florida Department of Corrections contracted with Centurion of Florida LLC, 

to provide primary medical services to the inmates who are confined to the 

Department’s prison facilities. Centurion is tasked with providing the primary 

medical care for the inmates and for referring the inmates out for advance testing 

or treatment when the medical condition of a particular inmate is more involved.

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Centurion’s initial contract with the Florida Department of Corrections was 

commenced in 2016. Centurion agreed to provide medical services to Florida 

Prison inmates that is consistent with the American Correctional Association 

Standards and consistent with the National Commission on Correctional 

Healthcare Standards.

6. The contract price of the Centurion initial contract was $267,968,00 per year. The 

contract was renewed with the Florida Department of Corrections in 2018. The 

new contract ensured Centurion 1.5 billion dollars. 

7. Centurion is a subsidiary of Centene Corporation which is a company based in St. 

Louis, Missouri. Centene owns various different subsidiaries such as Centurion of 

Georgia, Centurion of Tennessee, Centurion of Arizona LLC and of course, 

Centurion of Florida LLC. Each of these entities exist essentially for one reason: to 

provide contractual health services to the various states inmates who are housed in 

state prisons.

8. Centurion and its parent company, Centene, has a troubling and a well-established

custom and practice of denying or limiting inmates vital and necessary services for 

the sake of enhancing the company’s bottom line. This history is clearly 

demonstrated by the numerous lawsuits that have been filed against Centurion, or 

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that are currently pending against Centurion for similar acts as those alleged in this 

complaint or for more egregious acts. 

9. Centurion also has a practice of limiting the amount of staff that is on duty at the 

prisons on a particular day. In 2016 Centurion was sued by a prisoner in a 

Tennessee jail who was forced to deliver her child in an unsterilized room and

without the assistance of OB/GYN doctor. The suit also claimed that Centurion 

denied the female inmate the medications that she needed related to the delivery 

process. 

10. In another Tennessee prison case Michael Langston was admitted to the prison 

infirmary which was operated by Centurion. The medical staff kept him there for a

period of two weeks after he suffered a stroke which caused a brain hemorrhage. 

The medical staff was aware that Langston was in need of a life-saving medical 

intervention but they decided to keep him at the prison infirmary to keep the 

related cost down. When Langston finally was transported to the hospital the 

paramedics noted that he did not have a pulse. Langston died shortly after arriving 

at the hospital.

11. Centurion provides medical service for inmates in the New Mexico prison system

as well. The family of Adonus Encinias recently brought a Wrongful Death lawsuit 

against Centurion for denying him adequate services and for failing to make an 

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effort to come up with an effective treatment plan to treat his severe mental illness. 

Adonus was provided inadequate medical service that did not comport with the 

National Commission of Healthcare Standards. Resultantly Adonus hung himself 

in his cell. Centurion was aware of Encinias’ severe mental health problems, but it 

did not want to incur the cost related to providing him adequate psychological 

testing and treatment.

12. Four hours prior to the hanging death of Adonus Encinias, an inmate in the same 

prison hung himself in his cell. Keith Richard Kosirog also suffered from severe 

mental illness. Prior to his successful attempt to kill himself he attempted suicide 

12 times. In the days and the months leading up to Kosirog’s death he and his 

family implored the Centurion medical staff to create an adequate treatment plan to 

help him deal with his severe mental disturbances. The medical staff inexplicably 

lowered Kosirog’s antipsychotic medications. Not long after his medications was 

lowered he hung himself in his cell. 

13. Another New Mexico inmate, Jerry Sisneros, also filed a lawsuit against 

Centurion. Sisneros claimed that he presented to the prison clinic complaining 

about chills and fever, radiating back pain and difficulty urinating. The Centurion 

doctor failed to do a thorough examination. Rather Sisneros was only given

medicine for a urinary infection. After he was discharged from prison he continued 

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to experience severe lower back pains and other debilitating symptoms. He went to 

a local hospital where he was diagnosed with a severe infection of the spine. That 

infection caused permanent damage to his spine. All together there have been two 

dozen lawsuits filed against Centurion by New Mexico prison inmates. Most, if not 

all, of these inmates claimed that Centurion denied them needed medical services 

and that Centurion has a custom and a practice of providing inmates inefficacious 

medical care for the sake of enhancing its bottom line. 

14. The Human Rights Defense Center filed a lawsuit against Centurion in which it 

alleged that Centurion was failing to respond to public records request that sought 

information regarding medical service that is being provided to inmates in the 

Florida prison system. Centurion denied the Human Rights Defense Center’s 

allegation but it refused to produce the requested documents.

15. Centurion has also been sued by inmates and the family of inmates that have died 

in the Mississippi state prisons. The well documented allegations against 

Centurion’s Mississippi operation were so acute that the state of Mississippi 

decided to end its relationship with Centurion before the contract period officially 

ended.

16. The most troubling allegations that have been made against Centurion have come 

from within their own ranks. In December of 2019 Ronda Scott filed a lawsuit 

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against Centurion, in the Northern District Court for retaliating against her after 

she reported their violations of the law to state and federal officials. The complaint 

alleged that Centurion was permitting unlicensed personnel to dispense medicines 

at the prison pharmacy and that Centurion was engaging in other unlawful actions 

which resulted in inmates, who were suffering from Hepatitis C, not being 

provided adequate care. Scott alleged all of Centurions actions were aimed at 

improving the bottom line.

17. When Scott initially observed the violations she reported them to her managers. 

Managers at the highest levels directed her to falsify the records to cover up the 

flagrant and very dangerous violations of the health laws. Scott was instructed to 

amend her initial report to cover up the violations. When she failed to comply 

management falsified the records themselves.

18. In 2020, Centurion parent company Centene, was sued by a shareholder of the 

company, Laura Wood.

19. Wood alleged in paragraph three of her complaint that Centurion has a long 

history of failing to provide proper healthcare to the prison populations by the 

various contracts that it has with different prison systems. In paragraph four of the 

complaint Wood alleged that Centurion provided substandard medical care at 

Parchman Prison, in Mississippi and other prisons. She also alleged that this 

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substandard care resulted in increasingly routine deaths of incarcerated individuals 

and unconstitutionally inadequate medical care.

20. At all times relevant to this lawsuit Defendant Centurion of Florida LLC provided 

the healthcare for the inmates confined in the Florida State prison system.

21. Centurion Florida LLC has an internal approval process that required the medical 

providers at the clinics to obtain prior approval when an inmate has to be referred 

out for testing, surgery or other critical care that cannot be provided at the prison 

facility. The doctors that are assigned to the various medical clinics were not 

permitted to directly refer an inmate to an outside medical provider. Rather, all the 

doctors were required to go through a multi-layered approval process. 

22. The quality of medical service that Cineus received in the Polk County 

Correctional Institute did not depart from Centurion’s corporate wide custom. 

Centurion’s outside medical services approval process involves different 

individuals, some of which are not doctors, nurses or other medical providers. The 

non-medical providers involved largely make financial determinations regarding 

whether the related expense connected to a referral an inmate to an outside medical 

provider is financially justified. The overarching consideration in the referral 

process is not the health and well-being of the inmate, but rather it is to keep the 

cost down which in turn increases the profit margins of Centurion. 

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The deceased, Gamaliel Cineus, was admitted to Polk County Correctional Facility 

with a scheduled release date of March of 2019. 

23. Shortly, after arriving at the facility he began to experience a burning sensation in 

his stomach and in his throat. He also informed the medical staff that he was 

experiencing shortness of breath. Thereafter, over the course of five months 

Gamaliel Cineus made several trips to the clinic complaining of various ailments 

but he consistently complained about shortness of breath. Each time he was not 

tested for medical conditions that could cause a shortness of breath.

24. In addition to complaining to medical staff, he complained to his family when they 

visited him at Polk County Correctional Institute. He told them that he was 

experiencing shortness of breath and that he did not believe the medical staff was 

taking his complaints seriously enough. He also told his family that the 

correctional staff accused him of malingering and that they threatened to put him in 

the box, an isolation cell, if he kept coming to the medical clinic. 

25. Gamaliel Cineus requested that his mother contact the Warden and/or the Polk 

County Correctional Institute medical staff to urge them to perform more 

diagnostic tests because the problem of shortness of breath was persisting and 

getting progressively worse. Theresa Cineus did in fact call the Polk County 

Correctional Institute and request that her son be given additional medical tests

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especially, to check for blood clots. She informed the medical staff that there was 

a family history of blood clots and that she was currently taking medication to 

address her blood clot condition. Withstanding her urgings, the medical staff did 

not test Gamaliel Cineus for blood clots.

26. On May 6, 2018 Gamaliel Cineus visited the medical clinic which was staffed by 

nurses and doctors who are employed by Centurion of Florida LLC. He was seen 

by an unknown medical staff member. When he presented to the clinic he 

complained of shortness of breath. The Centurion staff member took no effort to 

diagnose the nature or the origin of the shortness of breath. After a brief 

conversation with the medical staff member Cineus was sent back to his cell 

without receiving treatment for his symptoms. 

27. On August 5, 2018, Gamaliel Cineus visited the clinic again complaining about 

various ailments. As before the clinic was staffed by the medical providers who 

were employed by Centurion of Florida LLC. The medical provider that saw him 

that day is identified in his medical records as V. Poonia, RN. Poonia failed to 

takes steps to specifically pinpoint the medical origin of the various symptoms that 

Cineus complained about. Additionally, Cineus was not referred to an outside 

diagnostic care center for further treatment or further evaluation. 

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28. On August 18, 2018, Gamaliel Cineus visited the clinic complaining about various 

ailments. The medical provider that saw him that day is identified in the medical 

records R. Hernandez, RN. R. Hernandez was a Registered Nurse that was 

employed by Centurion.

29. On October 18, 2018, Cineus presented to the clinic for an unspecified reason. 

Cineus was seen by two medical professionals on that day: D. Brown, RN and Dr. 

L. Ortiz.

30. On, October 23, 2018, Gamaliel Cineus visited the clinic. He was seen by a 

medical staff provider who is identified in the medical records as L. Perez, LPN. 

He did not receive treatment, nor was he referred out for appropriate diagnostic 

evaluation.

31. On October 30, 2018, Cineus reported to the clinic complaining of shortness of 

breath. The medical service provider is identified as V. Gonzalez, RN. Gonzalez 

marked the visit as routine she took no further action to flesh out the origin or 

cause of the shortness of breath. 

32. On November 1, 2018, Cineus presented to the clinic complaining of generalized 

weakness and heart palpitations. The medical provider on that day is identified as 

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K. Ingrando, RN. Cineus was discharged back to his dorm without further 

treatment and diagnostic testing. 

33. On November 9, 2018, Cineus reported to the clinic complaining of shortness of 

breath. The medical records indicate that the medical professional who treated 

him/examined him was Gonzalez, RN. 

34. On November 14, 2018, Cineus presented to the clinic again complaining of 

shortness of breath. He was seen by Gonzalez, RN. Withstanding the fact that 

Cineus was complaining about shortness of breath again, Gonzalez marked the 

visit as routine. No follow-up diagnostic testing was ordered.

35. On November 26, 2018, Cineus presented to the clinic again this time he was 

complaining about shortness of breath and weakness. Gonzalez, RN was the 

medical service provider. Gonzalez marked the medical report as a routine visit 

and no further diagnostic treatment or action was taken. 

36. On December 5, 2018, Cineus reported to the clinic complaining of abdominal 

pain. He was seen by Gonzalez, RN. However, no further diagnostic testing was 

done.

37. On December 19, 2018, Gamaliel Cineus went to the prison clinic again. This 

time he complained that the shortness of breath problem was becoming 

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progressively worse. He was seen by a medical provider identified only as 

Gonzalez, RN. Gonzalez did not refer Mr. Cineus for additional diagnostic 

screenings withstanding the fact that Gamaliel Cineus had complained multiple 

times before about shortness of breath and generalized weakness.

38. On December 21, 2018, Gamaliel Cineus returned to the medical clinic to report to 

them that the Pepcid that they gave him for heartburn was not working and that he 

was still having the same medical issues. The medical records indicate that he was 

seen by a medical provided identified as Gonzalez. Pepcid was given to the 

inmates regularly for symptoms that suggest far more serious morbidity. Again, 

Centurion did this for one purpose, to save money. Gonzalez knew or should have 

known that the symptoms that Cineus presented with suggested a potentially life 

threatening condition. 

39. Again on December, 23, 2018, Gamaliel Cineus reported to the medical clinic 

with largely the same issues. He complained about burning in his chest and he was 

continuing to experience shortness of breath. He was instructed to remain on the 

antacids. The medical provider that saw him on that day is identified in the medical 

records as V. Poonia, RN. 

40. On December 24, 2018, Gamaliel Cineus blacked out in the chow hall, the 

cafeteria. Prior to his blackout, he felt weak and was barely able to walk to and 

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from the cafeteria. Cineus was seen in the clinic on this day by two different 

medical providers: D. Jarvis, LPN and S. Baker, RN. He was finally referred to 

the medical doctor for follow-up.

41. On December 26, 2018, Gamaliel Cineus collapsed in his cell and remained there 

for a period of time while the correctional staff carried on their routine duties. 

Gamaliel Cineus’ roommate had to alert the correctional staff that there was 

medical emergency involving him. Once the correctional staff eventually entered 

his call, he was discovered to be lifeless and unconscious by staff he was 

transported to the medical unit. The medical staff did not immediately summons 

outside emergency medical help. The medical evidence shows that Cineus 

experienced medical distress as early as 5:00 am on this day but he was not 

transported until 7:53 am. Cineus died later that day. Dr. L. Ortiz was the 

attending physician that day.

42. After his death, the Polk County Medical Examiner’s office conducted a complete 

autopsy. Overall, Gamaliel Cineus was determined to be in good health. However, 

the cause of death was determined to be due to a pulmonary embolism, a blood clot 

in the lungs.

43. The suffering and the subsequent death of Gamaliel Cineus was directly caused by 

the policies, customs and the practices of Centurion of Florida LLC. These 

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customs, practices and policies caused Centurion to consistently ignore or to 

provide ineffective medical treatment to Gamaliel Cineus’ very serious medical 

condition, which was pulmonary embolism.

V. CAUSES OF ACTION 

COUNT I 

Violation of Civil Rights Pursuant to 

Title 42 U.S.C. §1983 As to Centurion of Florida LLC only

(Deliberate Indifference)

44. The Plaintiff incorporates by reference as though fully stated herein the allegations 

contained in paragraphs of 1-43.

45. Early on in the year 2018 the Department of Corrections was made aware that 

Gamaliel Cineus was suffering from a serious medical condition that required 

prompt and aggressive medical intervention. The medical staff who were 

employees of Centurion, knew that shortness of breath is a symptom that could be 

indicative of a myriad of serious medical conditions, some of which are life 

threatening. Just before Gamaliel Cineus died, he implored his mother to contact 

the Warden to direct Centurion’s medical staff to take his deteriorating medical 

condition more seriously. His mother did contact the Warden as well as the 

medical staff at the prison. No actions were taken to address the problem.

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46. From May 6, 2018 to December 24, 2018 Gamaliel presented to the medical clinic

which was staffed by Centurion medical personnel. He presented time and again 

complaining of various serious ailments. Most consistently, as laid out in 

paragraphs 1-43, Cineus complained about an increasing problem of shortness of 

breath and generalized weakness. He was given antacids by the medical staff and 

threatened with solitary confinement by the correctional staff for continuing to 

complain about his worsening medical condition.

47. The medical staff demonstrated a deliberate indifference and a reckless disregard 

for the demonstrably deteriorating health condition of Gamaliel Cineus. Although 

he complained about shortness of breath, which was indicative of various serious

health conditions, Centurion’s medical staff failed to refer him for diagnostic 

testing outside of the facility. The rationale and the reasoning for the deliberate 

indifference was that the company cared more about its financial health than it did

about the health of the inmates that it contracted to provide medical care to. 

Resultantly, Centurion refused to refer Cineus out for diagnostic services or to 

refer him out for interventional treatment. Instead, the medical staff remained 

focused on preserving the company’s bottom line. They offered Gamaliel Cineus 

antacids and attempted to intimidate him and to dissuade him from seeking further 

medical attention.

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48. Centurion’s treatment of Cineus’ shortness of breath was clearly and grossly 

incompetent. It was also excessively substandard to the point of shocking the 

conscience. The treatment of Gamaliel Cineus also sharply departed from the 

National Commission on Correctional Healthcare Standards.

49. On December 26, 2018, the day that Gamaliel Cineus died, the Defendant’s 

correctional and medical staff was aware of his medical distress as early as 5:00 

am but EMS services were not summons until 7:53 am, almost three hours after the 

medical crisis was first known to the Defendants.

50. Gamaliel’s medical condition overall, became progressively worse because of the 

Defendant’s inefficacious treatment of his shortness of breath with antacids. His 

continued shortness of breath is of such a nature that it would have alerted a lay 

person with no particularized medical training, that Cineus needed immediate 

medical intervention medical treatment. 

51. Although the Centurion medical staff provided Cineus some type of medicine at 

times such as Zantac, it does not mean that he was ever provided adequate or 

appropriate medical care. In fact, the level of care that was provided each and 

every time that he went to the clinic complaining about shortness of breath was so 

completely substandard that it was the equivalent of him receiving no treatment at 

all. 

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52. Centurion’s deliberate indifference was the direct and the proximate cause of the 

suffering and the death of Gamaliel Cineus. 

COUNT II 

Violations of Civil Rights Pursuant to 42 USC 1983 As to 

Centurion of Florida LLC

(Custom and Practice)

53. The Plaintiff incorporates by reference as though fully stated herein the allegations 

contained within paragraphs 1-43.

54. At all times relevant to this lawsuit Centurion had a custom, practice and policy that 

placed the health of Florida inmates, as well as all other inmates at various facilities, 

below the pursuit of corporate profits. 

55. As shown by the numerous lawsuits that have been filed and are currently being 

filed, Centurion’s handling of Gamaliel’s acute medical condition was consistent 

with how Centurion treats inmates in every prison that it provided private medical 

services. Centurion repeatedly denied Gamaliel adequate and appropriate medical 

care because it was Centurion’s custom to require multiple levels of authorizations 

before an inmate could be referred out for diagnostic or interventional services. The 

whole scheme was designed to dissuade Centurion medical staff from referring 

prisoners outside for potentially costly tests and services.

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56. Medical Staff were encouraged to and expected to do whatever it took to keep the 

cost down for delivering medical services to the inmates. This common design and 

policy resorted in the needless suffering and unnecessary deaths of several inmates 

throughout the Florida system, as well as throughout the nation, wherever Centurion 

was contracted to provide medical services to prisoners. 

57. The evidence of Centurions well-established custom of denying needful medical 

care to inmates is objectively documented by the fact that Centurion has been 

accused of the same acts which caused Cineus’s death in every state where it has 

been contracted to be a private medical provider. Further, some of Centurion’s 

former employees or shareholders have publicly acknowledged Centurion’s custom 

of placing the pursuit of financial gain above providing adequate and competent 

medical care to Florida inmates. 

58. As the direct and proximate cause of Centurions custom, policies and practices 

Gamaliel Cineus suffered great, physical and emotional harm. Gamaliel Cineus 

suffered the ultimate harm, he died because Centurion refused to refer him out for 

diagnostic and interventional services that Cineus clearly was in need of. Gamaliel 

Cineus died needlessly and his family loss a beloved member needlessly. 

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COUNT III 

Negligent Supervision As to Defendant Florida Department of 

Corrections only

59. The Plaintiff incorporates by reference as though fully stated herein the allegations 

contained in paragraphs of 1-43.

60. The Department contracted Centurion of Florida LLC to provide medical services 

to the inmates who are incarcerated in Florida prison facilities. Because the Florida 

Department of Corrections delegated the medical treatment of the inmates to 

Centurion it owed a duty to all inmates, imprisoned in the Florida prison system, to 

properly supervise the medical services that were being provided by Centurion.

61. The Defendants owed a duty to Gamaliel Cineus to ensure that the private medical 

contractor provide him with adequate medical attention once it was made aware 

that he had an emergent medical problem, to wit, he was suffering from persistent 

shortness of breath, abdominal pain and generalized weakness.

62. The Defendant breached its duty to Gamaliel Cineus, who at all relevant times was 

an inmate at the Polk County Correctional Institute, by not properly supervising the 

private medical contractor and thereby permitting it to provide Gamaliel Cineus 

with wholly infective and inappropriate medical care. Cineus was given antacids 

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despite the fact that he repeatedly complained about shortness of breath and 

generalized weakness.

63. Florida Department of Corrections did not require Centurion to abide by the 

National Healthcare guidelines and it failed to take corrective action against 

Centurion when it knew that it repeatedly provided grossly inadequate medical 

care to the individuals incarcerated within the Florida Correctional system.

64. The Defendant was further placed on notice that there was an emergent medical 

problem with Cineus because his mother called the Polk County Correctional 

Institute to complain about his ongoing problem with shortness of breath. She 

complained to medical staff and to the correctional staff that her son’s medical 

condition was getting worse. She expressly requested that they test her son for 

blood clots. 

65. As a direct and proximate cause of the Department of Corrections negligent 

supervision of the private medical contractor, Gamaliel suffered extreme physical 

discomfort, abdominal pain, generalized weakness and an increasing inability to 

breathe which culminated in his death on December 26, 2018. An autopsy 

conducted after his death revealed that the cause of death was a pulmonary 

embolism. 

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PRAYER FOR RELIEF

A. The Plaintiff demands all relief that is available under all pertinent Laws of the 

United States Constitution, federal statutes, the Common Law of the State of 

Florida and any and all relief that this Court may deem appropriate.

B. Compensation for loss of companionship, emotional pain, anguish and loss of 

consortium.

C. Reasonable attorney fees and reimbursement of all costs related to maintaining this 

action.

Dated: December 14, 2020

/s/ Jerry Girley

Jerry Girley, Esquire

FL. BAR # 0035771

THE GIRLEY LAW FIRM, PA

117 E. Marks Street, Suite A

Orlando, FL 32803

Tel: (407) 540-9866 

Fax: (407) 540-9867

phyllis@thegirleylawfirm.com

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CERTIFICATE OF SERVICE

I CERTIFY that on this 14

th day of December 2020 a true and correct copy of the 

Amended Complaint was filed using the Clerk of Court CM/ECF filing system and 

a copy provided via electronic mail to:

Brian A. Wahl, Esquire, bwahl@bradley.com, Bradley Arant Boult Cummings 

LLP, 1819 5th Avenue North, Birmingham, AL 35203 and Jacob B. Hanson, 

Esquire, jhanson@bradley.com, 100 North Tampa Street, Suite 2200, Tampa, 

Florida 33602.

/s/ Jerry Girley

Jerry Girley, Esquire

FL. BAR # 0035771

THE GIRLEY LAW FIRM, PA

117 E. Marks Street, Suite A

Orlando, FL 32803

Tel: (407) 540-9866 

Fax: (407) 540-9867

phyllis@thegirleylawfirm.com

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