Williams, et al v. City of Yazoo, et al, No. 20-61061 (5th Cir. 2022)
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A man detained at the Yazoo County Detention Center died after bleeding internally for hours. His survivors alleged that law enforcement officials knew that the man had been assaulted with a metal pipe and that he was vulnerable to internal bleeding if injured, yet they ignored requests for help from the man his family, and his fellow detainees, and left the man to suffer in his cell until it was too late. In rejecting the officials’ qualified immunity defense at summary judgment, the district court found numerous factual issues that, if resolved in Plaintiffs’ favor, would establish their liability on the federal denial-of-care claim. It did not, however, consider whether that constitutional violation was clearly established at the time of the man’s death.
The Fifth Circuit dismissed Yazoo City’s appeals for lack of jurisdiction, affirmed the district court’s denial of qualified immunity to the individual defendants on the federal denial-of-medical-care claim, and remanded for further proceedings. The court explained that it has granted qualified immunity when law enforcement misconstrued the symptoms of a serious medical condition for intoxication, or a less serious illness. Here, however, the officers’ knowledge of risk was based on much more than just symptoms: They also knew that the man had a life-threatening condition and had suffered trauma of the type that would trigger that condition. Those additional factors distinguish this case from the symptoms-only scenarios in Roberts and Cheney. Further, is clearly established that an official who refuses to treat or ignores the complaints of a detainee violates their rights.
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