Correction officers did not violate rights of pretrial detainee, who had gastrointestinal health issues from earlier gastric bypass surgery and had been placed on a specialized diet and prescribed antacids, for failing to call 911 in response to her initial complaints of abdominal pain, although she was scheduled to meet with doctor the next day, and when she did, he sent her to a hospital where she had surgery for a perforated ulcer; citing previous decision in Browner v. Scott Co., 14 F.4th 585 (6th Cir. 2021), and reviewing post-Browner cases in the Circuit, court rules that Kingsley changed the standard for denial of medical care to pretrial detainees and modified, but did not eliminate, the subjective prong; after a mind-numbing discussion, court articulates this test: “a plaintiff must satisfy three elements for an inadequate-medical-care claim under the Fourteenth Amendment: (1) the plaintiff had an objectively serious medical need; (2) a reasonable officer at the scene (knowing what the particular jail official knew at the time of the incident) would have understood that the detainee’s medical needs subjected the detainee to an excessive risk of harm; and (3) the prison official knew that his failure to respond would pose a serious risk to the pretrial detainee and ignored that risk.
Citation
Actionable Conduct Edition