Waldron v. Spicher, No. 18-14536 (11th Cir. 2020)
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Plaintiff, as the personal representative of her son, filed suit against a deputy, alleging that he violated her son's substantive due process rights under the Fourteenth Amendment by stopping several bystanders from performing CPR on her son after he attempted to commit suicide by hanging himself.
The Fourth Circuit vacated the district court's judgment and held that the district court analyzed this case under the erroneous assumption that a deliberate indifference level of culpability was sufficient. Rather, the court held that the deputy's actions cannot be deemed to violate clearly established substantive due process rights, unless the jury finds that he acted with a level of culpability more than reckless interference with bystanders' attempted rescue efforts. In this case, the court could not conclude that the deputy's reckless or deliberately indifferent interference with bystanders' rescue attempts is sufficient to constitute a violation of plaintiff's clearly established substantive due process rights. The court held that the deputy's actions would rise to that necessary level should the jury find that the deputy acted for the purpose of causing harm to plaintiff's son. The court explained that, if the jury finds that the deputy intended to cause harm to plaintiff's son in the form of death or serious brain injury, and finds the other circumstances it assumed in this summary judgment posture, then plaintiff would have proved a violation of clearly established substantive due process rights. Accordingly, the court remanded for further proceedings.
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