Patel v. Smith, No. 19-11253 (11th Cir. 2020)
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Plaintiff filed suit against a deputy sheriff and others, alleging that the deputy violated plaintiff's Fourteenth Amendment rights in two ways: (1) by using unconstitutionally excessive force when he placed plaintiff in an unventilated, un-air-conditioned transport van and kept him there for an unreasonable amount of time; and (2) by exhibiting deliberate indifference when he recklessly disregarded plaintiff's serious medical needs. Plaintiff also alleged state law claims. The district court granted the deputy's motion for summary judgment.
The Eleventh Circuit held that, although the deputy violated plaintiff's constitutional rights by applying excessive force, it was not clearly established at the time of his transport. Therefore, the court affirmed the district court's grant of summary judgment as to this claim. The court also held that the deputy exhibited deliberate indifference to plaintiff's serious medical need when he ignored plaintiff's resulting distress, which included unconsciousness, shaking, profuse sweating, and labored breathing. Furthermore, the deputy was on notice that he was confronted with a serious medical need and did nothing to aid plaintiff. Therefore, the deputy was not entitled to qualified immunity on the deliberate indifference claim. Finally, the court held that the district court erred in rejecting plaintiff's adjunct state-law claims on official immunity grounds.
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