Denial of Medical Care

Pretrial detainee died from epileptic seizure in cell; deputy not deliberately indifferent for failing to check on him when he observed him grunting under blanket because it would not have been obvious that he was having a seizure; deputy not deliberately indifferent for failing to transport detainee when he observed seizure while on medication rounds with nurse because he alerted nurse to “shaking” and detainee received medical care; issue of fact whether deputy was deliberately indifferent in allegedly waiting ten minutes to notify nursing staff that detainee was lying on floor of cell, f

Right to be free from deliberate indifference to symptoms including psychosis, fecal incontinence, and catatonia was clearly established; fact issues precluded summary judgment in favor of nurse, county, and sheriff.

Ddelirium tremens are objective serious medical need for purpose of due process claim; defendants must be analyzed individually, court cannot impute knowledge from one defendant to another.

Officers did not demonstrate objective unreasonableness or deliberate indifference when they failed to recognize that person arrested following stop for expired vehicle registration had overdosed on drugs, where she vomited, but denied withdrawing or detoxing, stated she had not eaten anything, stated she was sick, her stomach was turning, and she was pregnant, and officers found no drugs in her car.

Medical personnel of large, private, systematically organized, for-profit medical providers were not entitled to assert defense of qualified immunity; jail supervisors were not put on notice of a pattern of constitutional violations by two previous lawsuits.

Pretrial detainee suffered seizures as a result of discontinuance of her medications; court holds that Kingsley requires modification of the subjective prong of deliberate indifferent test; to impose liability, defendant must have acted or failed to act “intentionally to impose the alleged condition, or recklessly failed to act with reasonable care to mitigate the risk that the condition posed to the pretrial detainee even though the defendant-official knew, or should have known, that the condition posed an excessive risk to health or safety”; here jury could find a serious medical

Failure to treat convicted prisoner’s lump on his leg due to rupture of plantaris muscle with surgery did not violate his 8th Amendment rights; plaintiff received other care and surgery is not typically performed for that condition; only grossly or woefully inadequate care can be deemed “cruel and unusual” and to prove that generally requires medical evidence, typically expert testimony.

Pretrial detainee’s right to proper medical screening was clearly established, nurse could be liable for instituting alcohol withdrawal protocol rather than opiate withdrawal protocol, despite fact decedent told her of his heroin addiction; pretrial detainee had a right to direct-view safety check to determine whether his presentation indicated the need for medical treatment, but right was not clearly established prior to this opinion.

Court notes, but does not reach issue of whether Kingsley requires objective test on denial of medical care claim; court hold defendant was at most negligent and that would not meet either test for a constitutional violation.

Court find plausible claim against one officer for denial of medical care for prisoner who died from acute symptoms related to withdrawal from heroin, affords other officers qualified immunity; court assumes without deciding that severe opioid withdrawal constituted a sufficiently serious medical need; court concludes frequent vomiting alone does not present and obvious risk of severe and dangerous withdrawal, but that bloody vomiting witnessed by one officer does.