Carlos Hall, Sr. v. Eric Higgins, No. 22-2582 (8th Cir. 2023)
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Plaintiff was held in pretrial custody at the Pulaski County Regional Detention Facility (the Jail) in Little Rock, Arkansas, for five weeks. After he was released, Plaintiff filed a suit for damages against a Pulaski County official, alleging deliberate indifference to his medical needs, unconstitutional conditions of confinement, and disability discrimination. The district court granted summary judgment to the defendant on all of Plaintiff’s claims.
The Eighth Circuit affirmed summary judgment on Plaintiff’s Section 1983 deliberate indifference and conditions-of-confinement claims. But because triable issues remain on Plaintiff’s disability discrimination claim under the ADA and ACRA, the court reversed and remanded for further proceedings. The court explained that the record shows that Plaintiff indeed submitted “grievances” to the Jail complaining, for example, that he could not “stand up,” that he lacked help “changing or cleaning” himself, and that he could not “transfer to a toilet [and] back to the chair.” Moreover, at least one of Plaintiff’s disabilities—his paraplegia and the concomitant need for accommodations—was “obvious.” Thus, a genuine issue of fact exists regarding whether the Jail was on notice that Hall needed accommodations. Further, the court wrote that A viewing the evidence in the light most favorable to Plaintiff, a reasonable factfinder could conclude that the Jail failed to provide him with meaningful access to beds, toilets, and the identified medical care services.
Court Description: [Kelly, Author, with Gruender and Grasz, Circuit Judges] Civil case - Civil rights. Plaintiff alleged the defendant sheriff was deliberately indifferent to his medical needs and that he suffered unconstitutional conditions of confinement and disability discrimination while he was held in pretrial custody at the Pulaski County jail. On this record, no reasonable jury could find the jail deliberately disregarded plaintiff's serious medical needs, and without a constitutional violation, plaintiff's deliberate indifference claim fails; plaintiff's claim for unconstitutional conditions of confinement fails because he had not presented evidence of any official policy that restricts care to disabled inmates, and the pattern of behavior was not so pervasive or widespread as to establish an unofficial custom to deny such care; however, plaintiff has raised a genuine issue of fact with respect to whether the jail accommodated his access to toilet and bed access or denied him the same benefits as non-disabled detainees; the district court erred in granting defendant summary judgment on plaintiff's disability discrimination claim, and the matter is remanded for further proceedings on this claim.
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