Sanchez v. Young County, No. 19-10222 (5th Cir. 2020)Annotate this Case
After Diana Simpson died of a drug overdose while she was a pretrial detainee at the Young County Jail, her family filed suit under 42 U.S.C. 1983, alleging Eighth and Fourteenth Amendment violations, as well as a claim under the Texas Tort Claims Act. The Fifth Circuit previously affirmed summary judgment for the County in part, and remanded in part for the district court to evaluate plaintiffs' conditions-of-confinement theory in the first instance. On remand, the district court granted summary judgment on that theory and plaintiffs appealed.
The court affirmed the district court's dismissal of plaintiffs' claims based on a failure to train based on the law-of-the-case doctrine. The court held that the district court erred in dismissing plaintiffs' claims based on a failure to monitor because plaintiffs' evidence, when viewed in the light most favorable to them, creates several disputes of material fact about whether the jail has a de facto policy of inadequately monitoring detainees. Furthermore, plaintiffs offered sufficient evidence to create fact issues over whether the County failed to assess pretrial detainees' medical needs and whether this caused plaintiff to be denied needed medical care. Accordingly, the court reversed in part and affirmed in part, remanding for further proceedings.