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Eleventh Circuit Court of Appeals reverses district court’s dismissal of civil rights wrongful death lawsuit on grounds of qualified immunity, finds that whether prison guards were deliberately indifferent to inmate’s medical emergency must be determined b

On Aril 3, 2019, in Taylor v. Hughes et al, No. 17-14772, the Eleventh Circuit Court of Appeals reversed a Middle District of Alabama district court decision which had dismissed a  28 U.S.C. Section 1983 civil rights wrongful death lawsuit on the grounds of qualified immunity.  The estate of the decedent inmate had sued the guards of the jail in which the decedent had been held overnight after being arrested for a suspected DWI. During the night of his arrest and detention, the decedent allegedly spent several hours moaning and crying out in pain, telling the guards that he had in fact been in an accident prior to being arrested and that he was “all busted up.” The guards allegedly told him to “shut up” and refused to call for medical assistance.  The inmate died the next morning from internal bleeding. The Eleventh Circuit cited its previous decision in Mann v. Taser Int’l, Inc., 588 F.3d 1291, 1306–07 (11th Cir. 2009) for the general principle that to establish a constitutional deliberate-indifference claim, the defendant must demonstrate (1) the decedent had a serious medical need; (2) the defendants’ deliberate indifference to that need; and (3) causation between that indifference and the injury or death. Quoting from Mann, the Eleventh Circuit stated that a serious medical need is “one that has been diagnosed by a physician as mandating treatment or one that is so obvious that even a lay person would easily recognize the necessity for a doctor’s attention.” Id. at 1307.  Quoting from Goebert v. Lee County, 510 F.3d 1312, 1328 (11th Cir. 2007), the Eleventh Circuit further stated that  “[c]hoosing to deliberately disregard” an inmate’s complaints of pain “without any investigation or inquiry” is being willfully blind to pain.  The Eleventh Circuit concluded that there was enough evidence of a serious medical need and deliberate indifference to that need to preclude summary judgment. The Eleventh Circuit additionally concluded that the district court erred by requiring the plaintiff to present evidence that the guards knew the cause of the decedent’s injury and the specific nature of the decedent’s medical problem, noting that a guard does not need to know a detainee’s specific medical condition to be deliberately indifferent to his or her serious medical need.  See M.D. by Stukenberg v. Abbott, 907 F.3d 237, 252 (5th Cir. 2018) (concluding that courts do not require state officials to be warned of a “specific danger” to be held liable for deliberate indifference to a serious medical need).

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