Davis v. Buchanan County, Missouri, No. 20-1834 (8th Cir. 2021)
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Following the death of Justin Stufflebean after he allegedly was denied necessary medication while incarcerated, his parents filed suit alleging that the County and others were liable for wrongful death under Missouri law. The district court denied the County's motion to dismiss, concluding that the County had waived sovereign immunity by purchasing liability insurance that covered the wrongful-death claim.
The Eighth Circuit affirmed the district court's denials of the County's motion to dismiss, as well as a related motion for reconsideration, concluding that Mo. Rev. Stat. 537.610(1)'s plain text, bolstered by the statute's purpose and Missouri caselaw, shows that the County's acquisition of liability insurance in this case constitutes a waiver of its sovereign immunity. In this case, the County entered into an inmate-health-services contract with ACH; the contract contained an agreement to pay ACH approximately $300,000 per year; and, in exchange, ACH agreed to provide various services.
Court Description: [Gruender, Author, with Benton and Stras, Circuit Judges] Civil case - Civil rights. In this action alleging defendants, including the County, denied plaintiff's decedent proper medical care while he was incarcerated at the County jail, the district court did not err in determining that the County had waived its sovereign immunity by acquiring liability insurance when it entered into an inmate-care contract with defendant Advanced Correctional Healthcare. Judge Stras, dissenting.
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