McCaster v. Clausen, No. 11-2612 (8th Cir. 2012)
Annotate this CasePlaintiff had active tuberculosis at the time he was admitted to the Ramsey County Correctional Facility to serve fifty-six days for fifth degree assault. Plaintiff's condition worsened, and he was transferred to a hospital emergency room two days before he was scheduled for release. Plaintiff brought this action under 42 U.S.C. 1983, claiming that nursing staff, jail administrators, and the county had been deliberately indifferent to his serious medical needs in violation of the Eighth Amendment. The district court granted summary judgment on immunity grounds to the administrators and the county but denied summary judgment to five nurses. The Eighth Circuit Court of Appeals (1) reversed the denial of summary judgment to two of the nurses, as the evidence was insufficient to support a finding that these nurses deliberately disregarded a serious medical need; and (2) affirmed the denial of summary judgment to the remaining three nurses, as the evidence supported a finding that these nurses were deliberately indifferent to Plaintiff's serious medical need.
Court Description: Prisoner case - Prisoner civil rights. The district court erred in denying the motion for summary judgment based on qualified immunity as to defendant nurses Mattson and Darling as the evidence was insufficient to support a finding that plaintiff's illness was so obvious that they perceived a serious medical need and deliberately disregarded it; district court did not err in denying the remaining nurses' motion for summary judgment as the record could support a finding that they knew of his medical needs because they were obvious and failed to respond to them. Judge Bright, concurring in part and dissenting in part.
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