Rife v. McCurtain County Jail Trust, No. 16-7019 (10th Cir. 2017)Annotate this Case
This case began with plaintiff Clyde Rife, sitting on a motorcycle next to a road, unable to recall the date, the time, or even what he had been doing in a town he had just visited. When approached by a state trooper, Rife said that he was fine. Nonetheless, the trooper questioned Rife and concluded that he was intoxicated on pain medication and had been in a motorcycle accident. These conclusions led the trooper to arrest Rife for public intoxication. After the arrest, the trooper drove Rife to jail. Rife groaned and complained of pain in his heart and chest. Upon arriving at the jail, Rife was put in a holding cell. The scene was observed by a cellmate, who said that Rife had repeatedly complained about pain. Nonetheless, Rife was not provided medical attention. The arrest itself and the later lack of medical care led Rife to sue: (1) the trooper, two jail officials, and the entity operating the jail for deliberate indifference to serious medical needs; and (2) the Oklahoma Department of Public Safety for negligent failure to provide medical care. As a threshold question, the Tenth Circuit concluded probable cause existed to arrest Rife. With regard to his other claims, the Court found that the district court thought no one could reasonably infer either deliberate indifference or negligence. The Tenth Circuit disagreed, concluding that both could have been reasonably inferred from the evidence. The case was affirmed in part, reversed in part, and remanded for further proceedings.