Andrew Mattern v. City of Sea Isle
657 F. App'x 134
3rd Cir.2016Background
- After Hurricane Sandy, Andrew Mattern was driving a city truck slowly in reverse on a promenade and accidentally struck and killed pedestrian Bernice Pasquarello; visibility and hearing were impaired by bushes, earmuffs, wind, and the truck’s reverse beeper was not working.
- Police arrived; officers observed Mattern was visibly upset, emotional, crying, and said “I just killed someone.” Officers conversed with him, believed he was not physically impaired or intoxicated, and Mattern was able to recount the accident and make small talk.
- Mattern and his wife were detained temporarily at a makeshift police station, consulted an attorney, and left after a few hours; a deacon present to offer grief counseling was not permitted to speak with Mattern.
- Plaintiffs allege Mattern later developed PTSD, receives therapy, and that police denied him psychological/medical attention, causing constitutional harm.
- Plaintiffs sued under 42 U.S.C. § 1983 against four officers (named officers) and brought a Monell claim against the City for failure to train regarding psychological medical care; the district court dismissed under Rule 12(b)(6).
- The Third Circuit affirmed, concluding the complaint failed to plead (1) a sufficiently established "serious medical need" at the time of officers’ conduct and (2) officers’ "deliberate indifference," and therefore the Monell claim also failed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of post-accident psychological care to Mattern violated the Fourteenth Amendment (§1983) | Mattern needed immediate psychological/medical attention (PTSD) and officers ignored clear signs of distress, showing deliberate indifference | Officers observed Mattern was distraught but coherent, not physically impaired, and did not know of a serious medical need requiring a doctor; no constitutional deprivation | Dismissed: complaint fails to plead a serious medical need obvious at the time or officer knowledge showing deliberate indifference |
| Whether a post-hoc diagnosis suffices to establish a "serious medical need" for a denial-of-care claim | Post hoc diagnosis of PTSD and ongoing therapy show a serious medical need stemming from the incident | A diagnosis made after the officers’ conduct cannot establish that a serious need existed (and was obvious) at the time | Dismissed: post hoc diagnosis insufficient to satisfy the "serious medical need" prong |
| Whether officers’ observations (visibly shaken, "not ok") constitute deliberate indifference | Officers’ observations and refusal to allow grief counseling demonstrate they knew of the need and refused treatment | Observations show distress but not knowledge of a serious medical need or intentional refusal to provide medical care | Dismissed: allegations do not meet the subjective "deliberate indifference" standard |
| Whether the City is liable under Monell for failure to train re: psychological care | City failed to train responders to provide psychological/medical attention after accidents, causing constitutional violation | Municipal liability cannot stand because no underlying constitutional violation by officers occurred | Dismissed: Monell claim fails because no constitutional injury by employees was plausibly alleged |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading requires more than labels and conclusions)
- Monell v. Dep’t of Soc. Servs. of N.Y., 436 U.S. 658 (municipal liability requires underlying constitutional violation caused by policy or custom)
- Natale v. Camden Cty. Corr. Facility, 318 F.3d 575 (Fourteenth Amendment denial-of-medical-care standard for pretrial detainees)
- Monmouth Cty. Corr. Inst. Inmates v. Lanzaro, 834 F.2d 326 (definitions of "serious medical need" and examples of deliberate indifference)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference is a subjective standard)
- City of Los Angeles v. Heller, 475 U.S. 796 (no municipal liability if employee inflicted no constitutional injury)
- Bd. of Cty. Comm’rs v. Brown, 520 U.S. 397 (stringent standard for municipal liability and constitutional torts)