Donna Reece v. S. Williams, No. 21-4016 (8th Cir. 2023)
Annotate this Case
Plaintiff filed a 42 U.S.C. Section 1983 lawsuit stemming from her son’s death while under the supervision of employees at an Arkansas jail. She alleged that Defendants were deliberately indifferent to her son’s serious medical needs. The district court denied Defendants’ motion for summary judgment based on qualified immunity.
The Eighth Circuit reversed. The court explained that it disagreed with the district court’s opinion that a layperson would recognize seizure-like activity as a serious medical need that one of the Defendant’s deliberately ignored. The court reasoned that a reasonable jury could not conclude from this description of events that Defendant was aware of a serious medical need. Second, a reasonable officer would not necessarily infer that seizure-like activity in these circumstances required him to take additional action. The decedent was behaving normally at booking, though very thirsty and reportedly under the influence of methamphetamine. It isn't unreasonable to believe that whatever medical episode he experienced during transport (if he actually experienced one) had fully resolved itself by the time Defendant encountered him.
Further, the court explained that in these circumstances, Defendants can't be faulted for presuming that the medical staff best knows the quantity and quality of information needed for assessments. And even though the decedent was obviously sick, recognizing that someone is sick is not the same as knowing that he is receiving inadequate care from a trained medical professional.
Court Description: [Arnold, Author, with Smith, Chief Judge, and Stras, Circuit Judge] Civil case - Civil rights. Plaintiff's decedent, Mr. Reece, died after being arrested and taken to the Benton County Jail after he allegedly swallowed a quantity of methamphetamine, and plaintiff alleged the defendants were indifferent to his serious medical needs; the district court denied defendants' motion for summary judgment based on qualified immunity, and they appeal. The district court did not err in holding that no reasonable juror would find that Mr. Reece's behavior during booking at the jail would have indicated a serious medical need; however, the district court erred in denying defendant Williams' motion for summary judgment based on its conclusion that Williams was told at booking that Mr. Reece had seizure-like activity on the way to the jail and the condition was a serious medical condition that Williams deliberately ignored; there is no authority clearly establishing that a jailer in circumstances sufficiently similar to these was obligated to summon medical assistance or relate to others what he had learned from the arresting officer; other jail defendants were entitled to rely on the opinion of medical staff as to Mr. Reece's condition, and they were entitled to qualified immunity; defendant McCain was also entitled to rely on the opinion of medical staff, and the record does not show she was deliberately indifferent to Mr. Reece's medical needs; as a result, she was entitled to qualified immunity.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.