Buckley v. Hennepin County, No. 19-3243 (8th Cir. 2021)
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Plaintiff filed suit alleging 42 U.S.C. 1983 compensatory and punitive damage claims against paramedics for injecting her with ketamine without her consent, and against physicians who allegedly implemented ambulance protocols while conducting the second ketamine study, both in their individual and official capacities. Plaintiff also alleged claims of Monell liability against the county, several of its health care facilities, and the individual defendants for developing and implementing a countywide ketamine protocol. The complaint alleged that defendants used excessive force, violated her right to bodily integrity, and acted with deliberate indifference in violation of the Fourth Amendment and her right to substantive due process under the Fourteenth Amendment.
The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims. In regard to plaintiffs' claims against the paramedics, the court concluded that the district court properly dismissed plaintiff's excessive force claims where it was not objectively unreasonable for paramedics to administer medical aid to an intoxicated, suicidal, semi-conscious woman who needed medical intervention; the district court properly dismissed the substantive due process claims where, even if the semi-conscious plaintiff was competent to refuse treatment, the paramedics did not engage in conscience shocking conduct in electing to sedate a suicidal, intoxicated woman to protect both the patient and themselves; and the paramedics were not deliberately indifferent to plaintiff.
In regard to claims against the physicians, the court concluded that at minimum these defendants are entitled to qualified immunity on plaintiff's claims related to their oversight of the county's ketamine studies because they were not personally involved in the actions leading to plaintiff's emergency treatment. Finally, in regard to the Monell liability claims, the court concluded that plaintiff failed to establish that the paramedics violated her Fourth Amendment or substantive due process rights.
Court Description: [Loken, Author, with Smith, Chief Judge, and Gruender, Circuit Judge] Civil case - Civil rights. Allegations that paramedics used excessive force when restraining and sedating plaintiff are analyzed under the well-established objective reasonableness standard; it was not objectively unreasonable for paramedics to administer sedation to an intoxicated, suicidal, semi-conscious woman who needed medical intervention, and the district court properly dismissed plaintiff's excessive force claims against the paramedics; the paramedics' use of ketamine to sedate plaintiff did not violate her substantive due process rights as their conduct does not shock the conscience; the paramedics were not deliberately indifferent to a substantial risk of serious medical complications; with respect to the defendant doctors, they were entitled to qualified immunity on plaintiff's claims related to their oversight of the County's ketamine studies because they were not personally involved in the actions leading to plaintiff's emergency treatment; because plaintiff failed to show that the paramedics violated her Fourth Amendment or substantive due process rights, the Monell claims against the County were properly dismissed. Judge Gruender, concurring in part and concurring in the judgment.
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