Alfredo Miranda v. County of Lake
900 F.3d 335
| 7th Cir. | 2018Background
- In Oct–Dec 2011 Lyvita Gomes, a noncitizen detainee, refused food and fluids while in Lake County Jail; she was monitored by Correct Care Solutions (CCS) medical staff, placed on suicide watch, and eventually transported to a hospital on Dec 29; she died Jan 3, 2012 from complications of starvation and dehydration.
- The Estate sued under 42 U.S.C. § 1983 (Fourteenth Amendment due process), Illinois state tort and malpractice claims, ADA and treaty theories against Lake County, jail officials, CCS, two physicians (Drs. Elazegui and Singh), and social workers.
- District court granted summary judgment for county defendants (Monell and individual claims), dismissed some individual defendants on Rule 50(a) grounds mid-trial, and submitted only a limited inadequate-care (pain-and-suffering) due-process claim to the jury; jury found one social worker liable and awarded $119,000.
- At close of the Estate’s case, the district court directed judgment as a matter of law for the medical defendants on causation for Gomes’s death; the Estate appeals that ruling and other evidentiary/instruction rulings.
- Seventh Circuit affirms summary judgment for county defendants but reverses and remands for new trial on causation and related due-process theories against the two physicians, and holds the district court abused discretion by barring the failure-to-protect-from-self-harm theory.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| County individual liability (deliberate indifference) | Hunter and Fitch knew or should have known medical care was inadequate and failed to act. | They reasonably relied on medical professionals and repeatedly sought updates. | Affirmed for defendants: nonmedical jail officials entitled to rely on medical staff; no deliberate indifference. |
| Monell claim re: hunger-strike policy | Jail policy was deficient (notification timing, follow-up, suicide-history checks) and caused harm. | Policy had reasonable safeguards; single incident insufficient to show deliberate indifference/causation. | Affirmed: policy not shown to be deliberately indifferent or a proximate cause of death. |
| Vienna Convention Article 36 (consular notice) | Failure to re-notify Gomes of consular rights in Dec. violated treaty and § 1983. | Qualified immunity: it was not clearly established in 2011 who beyond booking officers qualified as "competent authorities." | Affirmed on qualified immunity grounds; no clearly established duty beyond booking officer. |
| Causation for death (medical defendants) | Delay/inaction by Drs. Elazegui and Singh proximately caused or diminished Gomes’s chance of survival; expert testimony and autopsy support causation. | Evidence insufficient: no expert tying autopsy cause to defendants’ actions or events during hospital stay; judgment as matter of law appropriate. | Reversed: factual record (autopsy, experts, docs) could support inference that delay reduced survival chance; new trial ordered. |
| Applicable intent/standard for pretrial detainee medical claims | Estate: due-process claim may proceed under Fourteenth Amendment applying objective unreasonableness per Kingsley. | Defendants: Fourteenth claims should retain subjective deliberate-indifference standard akin to Eighth Amendment (prisoner cases). | Court adopts Kingsley framework: for pretrial detainees medical-care claims, the inquiry is whether defendants’ conduct was objectively unreasonable (no subjective awareness required), while still requiring more than mere negligence. |
Key Cases Cited
- Greeno v. Daley, 414 F.3d 645 (7th Cir. 2005) (division of labor: nonmedical staff may rely on medical professionals)
- Rice ex rel. Rice v. Corr. Med. Servs., 675 F.3d 650 (7th Cir. 2012) (reliance on medical staff shields nonmedical officials; failure-to-protect jurisprudence)
- Kingsley v. Hendrickson, 135 S. Ct. 2466 (2015) (pretrial-detainee excessive-force claims use an objective-unreasonableness standard)
- Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (1978) (municipal liability for constitutional violations by policy or custom)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard in failure-to-protect and medical contexts)
- West v. Atkins, 487 U.S. 42 (1988) (private physicians acting under contract are state actors under § 1983)
- Williams v. Liefer, 491 F.3d 710 (7th Cir. 2007) (verifying medical evidence required to prove delay caused harm in constitutional medical claims)