Jail detainee died from methamphetamine overdose, jury could find that nurse who failed to
render any treatment was deliberately indifferent to need for medical attention but not
that deputies acted unconstitutionally; plaintiff not required to prove that nurse was
aware that detainee had ingested lethal dose of meth if need for medical attention
based on severe symptoms was obvious even to non-medical professionals.
Where officer shot subject several times and watched him crash into a tree, and officer radioed for police backup for himself, it would violate clearly established law for officer to stand by for six minutes without performing medical care or call for medical backup.
Use of force, tasing, holding prisoner in prone position on his chest was obviously the wrong treatment for one having an epileptic seizure and officers acted with deliberate indifference in delaying prisoner’s access to emergency medical care by delaying EMTs’ access to prisoner, by using restraint chair, and failing to properly respond to fact that his breathing and heart had been compromised.
Jail officers could be held liable for failing to give prisoner prescribed medications for a back injury, attention deficit disorder, gastroesophageal reflux disease, and insomnia and would not be entitled to qualified immunity.
Pretrial detainee in sickle cell crisis was not transported to hospital, but strapped in restraint chair with minimal observation and died four hours later; crisis was objectively serious medical need; issue of fact as to whether nurse acted recklessly in failing to send detainee to E.R.
Pretrial detainee with back injury, attention deficit disorder, gastroesophageal reflux disease, and insomnia had serious medical needs; denial of prescription medications demonstrated deliberate indifference.
Sickle cell crisis was objectively serious medical need; fact issues precluded summary judgment for nurse who failed to send detainee to ER and officer who failed complete required checks on detainee in restraint chair; other nurse’s conduct of failing to call doctor or perform further checks on detainee in restraint chair was not deliberate indifference.
Convicted prisoner had twice before been placed on suicide watch, then released from it; over three week period got into fight with another prisoner, acted distant, had abrasions on wrist, was unkempt, not eating, lost weight, slept poorly, stated he “needed help,” falsely accused cell mate of raping him; then committed suicide ten days later after asking for his cellmate to be removed; court holds even if prisoner should have been moved to suicide watch due to incidents during the three week period, there were no signs of suicidal behavior ten days later when he committed suici
Pretrial detainee in withdrawal from alcohol or drugs with severe vomiting and diarrhea, treated only with two doses of antiemetics prescribed by fax by doctor who never saw him died five days after arrest; court reviews impact of Kingsley on standard and concludes elements for pretrial detainee’s claim are now: “(1) that [plaintiff] had a sufficiently serious medical need and (2) that each defendant acted deliberately (not accidentally), [and] also recklessly in the face of an unjustifiably high risk of harm that is either known or so obvious that it should be known”;
If officers knew deceased had swallowed a bag full of drugs, vomited multiple times, screamed for help, pleaded to go to hospital, and steadily deteriorated, and ignored or failed to treat him, they violated his clearly established rights, even if they monitored him, provided sustenance, spoke with him, and cleaned him and his cell, because they were not addressing his serious medical needs.