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Ignoring a detainee’s need for medical treatment was deliberate indifferent in violation of the Eighth Amendment

 

After Almus Taylor died from internal bleeding after being kept in a jail holding cell overnight, Almus’s father Bonny Taylor sued the jail guards under 42 U.S.C. §1983 and Alabama state law alleging that they were deliberately indifferent to Almus’s serious medical needs. After the district court dismissed Bonny’s claims based on qualified immunity, he appealed to the Eleventh Circuit court of appeals raising the question whether qualified immunity shields the guards from Bonny’s constitutional deliberate indifference claim.

These are the background facts. Taylor was found in a battered pickup truck by a Covington County Deputy who called Emergency Medical Services and Alabama Highway patrol. While the EMS offered to take him to the hospital, he refused because they could not accommodate his request that he bring his dog along. The Alabama state trooper then arrested Almus for driving under the influence and took him to jail.

Upon arrival at the jail three guards noticed he appeared to be highly intoxicated. The Alabama State trooper told them he had been medically cleared though the booking medical log indicated Almus’s statement that he was all busted up from a car wreck. There was dispute about whether Almus cried out for help during the night and whether the guards heard his cries. Other detainees said he spent several hours moaning and crying out in pain. None of the guards called for medical help. The jail nurse called 911 after her early the next morning and he died on the way to the hospital from internal bleeding.

In his appeal Bonny contended that guards violated Almus’s constitutional rights by being deliberately indifferent to his serious medical needs. Under the eight amendment prisoners have a right to receive medical treatment for their illnesses and injuries. Deliberate indifference to the serious medical needs of a prisoner is therefore a constitutional violation and Almus was protected to the same extent as prisoners under the Fourteenth Due Process Clause.

To establish his deliberate indifference claim Bonny had to demonstrate that 1) Almus had a serious medical need and 2) the defendant’s deliberate indifference to that need, and 3) causation between that indifference and Amus’s injury. The district court found insufficient evidence to raise a genuine dispute of material fact regarding the first two elements.

As to the first element the conflict in the testimony presents a genuine dispute of material fact as to whether Amus had a serious medical need. If Almus was begging for medical help, crying out in pain and informing the guards that he was dying, then a reasonable jury could conclude that a lay person would recognize the need for a doctor’s attention.

The court of appeals held that a civil rights constitutional violation claim could proceed on the basis of deliberate indifference to a serious need  because it constitutes the unnecessary and wanton infliction of pain proscribed by the Eighth Amendment. Choosing to deliberately disregard an inmate’s complaints of pain without any investigation or inquiry is being willfully blind to pain. The court concluded that a reasonable jury could conclude the the guards were not entitle to rely on Trooper Amis’s statement that Almus was just drunk. In addition a jury could conclude that the guards’ willful disregards of what they heard and observed during the night made them deliberately indifferent to Almus’s serious medical needs.