Taylor v. Hughes, No. 17-14772 (11th Cir. 2019)Annotate this Case
After Almus Taylor died in a jail holding cell, plaintiff filed suit against the jail guards under 42 U.S.C. 1983 and Alabama law, alleging deliberate indifference to Almus's serious medical needs.
The Eleventh Circuit reversed the district court's dismissal and held that qualified immunity did not shield the guards from plaintiff's deliberate indifference claims where a reasonable jury could conclude that the guards were not entitled to rely on a trooper's statement that Almus was just drunk, particularly because Almus reported injuries from a car accident. Furthermore, a reasonable jury could conclude that the guard's willful disregard of what they heard and observed during the night made them deliberately indifferent to Almus's serious medical needs, and the district court erred by requiring plaintiff to present evidence that the guards knew the cause of Almus's injury and the specific nature of his medical problem. The court also held that the state agent immunity and Alabama Code 14-6-1 did not shield the guards from plaintiff's state law claims if the guards potentially violated Almus's constitutional rights.