Benton County Jail staff can’t be held responsible for man’s death in custody, court rules

A view of a cell block at the Benton County Jail on Thursday July 30, 2015 in Bentonville. (NWA Democrat-Gazette/BEN GOFF)
A view of a cell block at the Benton County Jail on Thursday July 30, 2015 in Bentonville. (NWA Democrat-Gazette/BEN GOFF)

A federal appeals court Tuesday reversed 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 died while under the supervision of employees the Benton County Jail. 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 on the ground of 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 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 that he was taken to a nearby hospital where he was pronounced dead, according to the opinion.

An autopsy report concluded it was likely that 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 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 that a layperson would recognize seizure-like activity as a serious medical need that was deliberately ignored.

The appeals court disagreed, saying a reasonable jury could not conclude from the description of events that jail employees were aware of a serious medical need and that a reasonable officer would not necessarily infer that 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 he continued to be monitored by two nurses. After less than an hour in the detox cell, medical staff decided to call an ambulance and have Reece taken to a local 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, according to the opinion.

"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.


Qualified immunity

Protects public officials from being sued for damages unless they violated “clearly established” law of which a reasonable official in his position would have known. It aims to protect civil servants from the fear of litigation in performing discretionary functions entrusted to them by law. Government officials performing discretionary functions generally are shielded from liability for civil damages as long as their conduct doesn’t violate clearly established statutory or constitutional rights of which a reasonable person would have known.

Source: uslegal.com

 

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