Morris v. Cradduck, No. 17-3079 (8th Cir. 2020)
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Plaintiff, a former detainee at the detention center, filed suit against the sheriff and nurse, alleging that defendants delayed his access to adequate medical treatment for a serious condition while he was detained.
The Eighth Circuit affirmed the district court's grant of summary judgment in favor of defendants, holding that there was insufficient evidence to support a submissible case. In this case, the nurse's actions demonstrated concern for plaintiff's condition and showed repeated efforts to make arrangements for surgery. Even if the nurse could be second-guessed for not acting more aggressively when the doctor's office delayed, her handling of the situation was at most negligent and does not amount to deliberate indifference that violates the Due Process Clause. Because plaintiff has not presented sufficient evidence that the nurse was deliberately indifferent to his serious medical needs, it follows that the sheriff did not violate plaintiff's rights by supposedly turning a blind eye to his complaints about the nurse. Likewise, claims against defendants in their official capacities, which are treated as claims against the municipality, failed for lack of a constitutional violation.
Court Description: [Colloton, Author, with Loken and Erickson, Circuit Judges] Civil case - Civil rights. In action alleging defendants, through their individual actions and the customs and policies of the county, delayed the plaintiff's access to adequate medical treatment while he was a detainee at the Benton County Detention Center, the district court did not err in granting summary judgment in favor of the Sheriff and jail nurse; the record showed the nurse demonstrated concern for plaintiff's condition and made repeated efforts to arrange for surgery to address his condition; even if she should have acted more aggressively, her handling of the situation was at most negligent and did not rise to the level of constitutional violation; given that plaintiff failed to show the nurse, who worked under the Sheriff, violated the Constitution, the sheriff did not violate plaintiff's right by supposedly turning a blind eye to his subordinate's actions.
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