A federal appeals court Tuesday reversed a ruling by a lower court judge, ruling employees at the Benton County jail are entitled to qualified immunity in a civil rights lawsuit filed by the family of a man who died from ingesting methamphetamine after he was arrested and taken to jail.
Amos Reece of Delaware County, Okla., died on Feb. 25, 2018 while under the supervision of employees of the jail. He was 43.
His mother, Donna M. Reece, sued four jail employees, claiming they were deliberately indifferent to Reece’s serious medical needs. The jail employees moved for dismissal of the suit based on qualified immunity. The district court judge denied their motion, and they appealed the ruling.
Reece was arrested in the middle of the night after he reportedly tried to break into vehicles in a hospital parking lot, according to an opinion rendered by a three-judge panel of the 8th U.S. Circuit Court of Appeals. He was booked into the Benton County jail. Over the next few hours his medical condition deteriorated to the point he was taken to a nearby hospital, where he was pronounced dead, according to the opinion.
An autopsy report concluded it was likely Reece orally consumed a quantity of methamphetamine within a small plastic bag. The bag subsequently opened in his stomach, leading to acute methamphetamine toxicity and his subsequent death.
Reece never told anyone at the jail about eating the methamphetamine, according to the opinion. The parties also disputed whether the arresting officer told jail employees Reece was under the influence of methamphetamine, but, for purposes of the appeal, judges assumed he did. There were also questions about whether Reece was exhibiting seizure-like activity while being transported to jail.
Defendants are entitled to qualified immunity if “their conduct does not violate clearly established constitutional rights of which a reasonable person would have known,” according to the opinion.
The district court denied qualified immunity, saying a layperson would recognize seizure-like activity as a serious medical need that was deliberately ignored.
The appeals court disagreed, saying a reasonable jury couldn’t conclude from the description of events jail employees were aware of a serious medical need and a reasonable officer wouldn’t necessarily infer seizure-like activity, under the circumstances, required them to take additional action.
About two hours after being booked into the jail, Reece began acting up and was placed in a restraining chair in an area where he could be better monitored, and he was examined by jail medical staff, according to the opinion.
Reece calmed down and was later taken to a detox cell, but two nurses continued to monitor him. Less than an hour later, medical staff decided to call an ambulance and have Reece taken to a hospital.
The appeals court judges said medical personnel were monitoring Reece within 10 minutes of his arrival at the jail. And, the jail employees were in no position to question the sufficiency of the nurse’s assessment of Reece, according to the opinion.
Prison officials lacking medical expertise are entitled to rely on the opinions of medical staff regarding inmate diagnosis and the decision of whether to refer the inmate to outside doctors, the opinion states.
“In the circumstances, the defendants can’t be faulted for presuming that the medical staff best knows the quantity and quality of information needed for assessments,” according to the opinion.