Janice Washington v. City of St. Louis, Missouri, No. 22-1843 (8th Cir. 2023)
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Plaintiff’s son spent several months at a medium-security facility in St. Louis called “the Workhouse.” None of the guards saw Plaintiff’s son receive or take fentanyl, the drug that killed him. Inmates tried to help by rubbing ice on him once he lost consciousness. Upon arriving a few minutes later, three Officers radioed for medical assistance. In the meantime, rather than try to resuscitate Plaintiff’s son themselves, they stood by and watched as two inmates tried to help him. When trained medical personnel finally arrived four minutes later, it was too late: they were unable to revive Plaintiff’s son, who died from an overdose. Surveillance footage captured some, but not all, of these events. Plaintiff’s mother sued the City of St. Louis, the three responding officers, and two supervisors for their deliberate indifference. The district court denied summary judgment to the responding officers.
The Eighth Circuit vacated and remanded. The court held that the district court misstated the burden and relied on allegations from an unverified complaint to deny summary judgment. The court wrote that the district court erred in how it dealt with the gaps in the video footage. Instead of relying on other evidence to fill in the missing details, the findings mirrored what the plaintiff’s unverified complaint said. The court wrote that unsworn allegations are no substitute for evidence at summary judgment. The court explained that the district court tilted the scales too far in the Plaintiff’s favor by raising the summary-judgment burden on the officers and allowing unsworn allegations to rebut evidence.
Court Description: [Stras, Author, with Benton and Grasz, Circuit Judges] Civil case - Civil rights. In action alleging the City, three responding officers, and two supervisors were deliberately indifferent to plaintiff's decedent's medical needs after he overdosed on fentanyl in the city jail, the district court denied the responding officers' motion for summary judgment, and they appeal. The district court did not apply the correct summary judgment motion standard; the officers could discharge their burden of proof on their motion by showing that the plaintiff had failed to come forward with evidence supporting her claims; in the absence of discovery in the case, the district court could not rely on plaintiff's unverified complaint to rebut the evidence the officers offered in support of their motion for summary judgment; the district court tilted the scales too far in plaintiff's favor by raising the summary-judgment burden on the officers and allowing plaintiff's unsworn allegations to rebut defendants' evidence; the denial of the motion for summary judgment is vacated, and the matter is remanded for further proceedings; on remand, the district court is free to reconsider its decision to stay discovery. [ October 18, 2023 ]
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