Shadrick v. Hopkins Cnty., No. 14-5603 (6th Cir. 2015)
Annotate this CaseButler, age 25, arrived at Hopkins County Detention Center to serve a misdemeanor sentence. A tower operator saw Butler put something in his mouth and swallow, and relayed her observation to deputies, who started booking procedures. Butler vomited twice. Deputies noticed that Butler appeared to be under the influence and was sweating profusely. While answering questions, his demeanor deteriorated and he had difficulty standing. Butler stated that he had an MRSA infection, high blood pressure, rheumatoid arthritis, gout, and osteoporosis. He listed several prescribed medications and denied drug or alcohol addiction. The deputies did not want to admit Butler because of his condition. A licensed practical nurse examined Butler and instructed the deputies to admit Butler. As an LPN, she lacked the credentials to diagnose any illness, but was aware that untreated MRSA infection could lead to sepsis and death. Although staff placed Butler on suicide watch, there is no evidence that Butler was evaluated for suicidal ideation, nor any evidence that Butler received blood pressure medication while confined or that the nurses questioned why his blood pressure fell, absent medication. Butler died three days later from MRSA complications. The court rejected claims under 42 U.S.C. 1983b on summary judgment. The Sixth Circuit reversed, noting genuine issues of material fact and that the facility's medical contractor is not entitled to governmental immunity on the state-law claim.
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