Letterman v. Farnsworth, No. 14-1571 (8th Cir. 2015)
Annotate this CaseDanial received a 120-day "shock" sentence for possessing marijuana. At the Missouri Western Correction Center, Danial was placed in the prison's "hospital" ward, where he beat on the walls. Following a request from mental health personnel, Danial was moved to a padded cell. He remained in a manic state, under the highest level of observation, requiring in-person checks for an affirmative response four times an hour. One night, staff merely viewed Danial through a monitor. Around 11:26 p.m., Danial fell and hit his head against a wall, slid down, and remained sitting until he fell backward again, hitting his head on the door jamb. Danial stated that he injured his head and needed medical attention. Staff did not open the cell door. They obtained no responses from Danial during the rest of the shift. Around 9:00 a.m., staff tried to wake him, even splashing water on Danial's face through a door opening. Danial responded by moving his eyes "slightly" and groaning. Danial had been in the same position, unresponsive for hours, but staff still did not open the door. When staff finally entered Danial's cell, his temperature was below 90 degrees, his pulse was between 30 and 34 beats per minute, and his eyes were fixed and dilated. He died in a hospital three days later, as a result of subdural hematoma caused by the falls in his cell. His parents sued under 42 U.S.C. 1983. The district court denied defendants’ motion for summary judgment on deliberate indifference claims, asserting qualified immunity. The Eighth Circuit reasoned that a jury could find two defendants liable for deliberate indifference, but that the conduct of a third officer constituted, at most, negligence.
Court Description: Melloy, Author, with Loken and Murphy, Circuit Judges] Civil case - Civil rights. Plaintiff's decedent who struck his head and suffered a fatal subdural hematoma while locked in a padded cell in the Missouri Western Reception, Diagnostic and Correction Center was at risk of suffering serious harm without medical attention, and a reasonable person in defendants Farnsworth's and Earls's position would have recognized a substantial risk of harm; defendants acted inappropriately in light of the risk by failing to summon medical care and were entitled to summary judgment based on qualified immunity; defendant Jennings took steps to abate the prisoner's situation, and while the actions might be considered insufficient or even negligent, she was not deliberately indifferent to his condition and was entitled to qualified immunity.
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