Davis v. Munger, No. 20-1842 (8th Cir. 2021)
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After Justin A. Stufflebean died after allegedly being denied necessary medication while incarcerated at the Buchanan County Jail and the Western Reception Diagnostic and Correctional Center, his parents filed 42 U.S.C. 1983 and wrongful death claims against defendants. The district court denied defendants' motions to dismiss and motions for summary judgment.
The Eighth Circuit concluded that it has found no firmly rooted history of immunity for private medical services providers and the purposes of qualified immunity, on balance, do not favor extending immunity to these defendants because employees of large firms systematically organized to perform a major administrative task for profit are not entitled to assert the defense of qualified immunity. The court dismissed their appeal based on lack of jurisdiction. This holding similarly precludes immediate appellate review of ACH and Corizon's appeals. The court also concluded that Defendants Strong and Hovey, the supervisors of medical care, were not on notice of a pattern of constitutional violations and their failure to verify the accuracy of ACH's reporting is insufficient to create liability under section 1983; Defendant Gross was not deliberately indifferent to defendant and is entitled to qualified immunity; Gross was also entitled to official immunity on plaintiff's wrongful death claim; but the jail's booking officer, Defendant Nauman, was not entitled to official immunity where his inconclusive testimony on accessing defendant's prior records precludes summary judgment on this issue. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings.
Court Description: [Benton, Author, with Gruender and Stras, Circuit Judges] Civil case - Civil rights. Plaintiffs alleged their son died from complications brought on by defendants' failures to provide necessary medications while he was incarcerated at the Buchanan County Jail and with the Missouri Department of Corrections; defendants moved for summary judgment and they appeal the district court's denial of their motions for qualified immunity and official immunity; the court has found no firmly rooted history of immunity for the private medical-services-providers, and the purposes of qualified immunity do not, on balance favor extending immunity; as a result, the medical doctor defendant and the three nurse defendants, as employees of large firms systematically organized to perform a major administrative task for profit, were not entitled to assert the defense of qualified immunity; their appeal is dismissed for lack of jurisdiction; similarly, this holding precludes immediate appellate review of the appeals by defendants ACH and Corizon; defendants Strong and Hovey, as supervisors of medical care, were not on notice of a pattern of constitutional violations, nor was their failure to verify the accuracy of ACH's reporting regarding grievances sufficient to create Section 1983 liability; defendant Gross, who brought plaintiff's decedent to the Jail was not deliberately indifferent to his medical needs as plaintiffs failed to show he had subjective intent to cause harm or that he could not reasonably believe that his response to booking officers was not deliberately indifferent or reckless; defendant Gross was entitled to official immunity on plaintiffs' wrongful death claim as his duty to report information was discretionary;the jail's booking officer was not entitled to official immunity for his actions in filling out the medical section of the deceased's booking form because of his inconclusive testimony on accessing prior medical records.
This opinion or order relates to an opinion or order originally issued on July 20, 2021.
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