Crowson v. Washington Co. State of Utah

Submitted by Re'Neisha Stevenson on Wed, 10/26/2022 - 00:42

Medical professional who knows that his role is to serve as gatekeeper for other medical personnel capable of treating a condition may be liable for deliberate indifference for denying access to medical care; nurse’s knowledge that plaintiff was “dazed and confused” and unable to remember what kind of work he did was sufficient to trigger nurse’s duty as gatekeeper; nurse was not deliberately indifferent because he referred plaintiff to a physician’s assistant; nurse’s failure to inform doctor of how long plaintiff had been in custody, which was allegedly too long to be suffering from withdrawal related to pre-incarceration drug use, was not deliberately indifference; Dr. was entitled to qualified immunity for misdiagnosis due to failing to complete plaintiff’s blood test where plaintiff’s symptoms were consistent either with withdrawal or encephalopathy because right was not clearly established; absence of constitutional violation by nurse defeated failure to train nurse claim against county; court lacked jurisdiction on interlocutory appeal to rule on broader claim that county’s failure to properly train nurses and guards, combined with policy of relying on largely absentee physician, evidenced deliberate indifference to plaintiff’s medical needs.

Actionable Conduct Edition