Jamie Leonard v. Steven Harris, No. 21-3755 (8th Cir. 2023)
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While in jail, Plaintiff clawed at his own eye with enough force to tear it out. Plaintiff sued nearly everyone involved, including St. Charles County, under 42 U.S.C. Section 1983. The district court concluded that none of the individuals involved had violated his Fourth, Eighth, or Fourteenth Amendment rights. Nor, in the absence of a constitutional violation or a county-wide custom of unconstitutional conduct, was St. Charles County liable for his injuries. The question is whether qualified immunity is available to those who may have prevented the injury.
The Eighth Circuit affirmed the district court’s judgment. The court explained that the record is devoid of evidence that the Officer and Sergeant consciously disregarded a serious medical need. And even if the Nurse’s failure to administer Plaintiff’s medications approached criminal recklessness, the court wrote, it cannot say that the law was so “clearly established” that she was on “fair notice” she was violating it. Further, Plaintiff cannot point to any court that has held that an officer was deliberately indifferent because he placed a pepper-sprayed inmate in a new cell with a sink.
Court Description: [Stras, Author, with Colloton and Wollman, Circuit Judges] Civil case - Civil rights. Jail officers sprayed plaintiff with pepper spray after he refused orders during a search of his cell; he subsequently clawed out his eye while confined in his cell, and he sued the jail officers, staff and jail for violation of his Fourth, Eighth and Fourteenth Amendment rights; the district court granted defendants' motion for summary judgment based on qualified immunity, and plaintiff appeals. Held: The officer's use of pepper spray was objectively reasonable under the circumstances; the officers and nurse who examined plaintiff after he was sprayed did not consciously disregard a serious medical need; decision to place plaintiff in a cell with a sink where he could wash his eyes, as opposed to taking him for additional treatment, was not a constitutional violation; decision by officer who observed plaintiff clawing his eye to await assistance before entering the cell was not deliberate indifference as plaintiff was in a frenzied state, was not handcuffed, and presented a serious safety risk to the officer; denial of plaintiff's medications in these circumstances did not violate clearly established law, and Nurse Martin was entitled to qualified immunity on the claim; on plaintiff's Monell claim, the county did not have a policy or custom of failing to give detainees medication; the district court did not err in determining that no adverse inference should be drawn from the deletion of a video as there was no evidence that the defendants had any intent to deprive plaintiff of the information's use.
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