Autry v. Cleveland County Sheriff's Department, 5:15-cv-01167

Background

Robert Autry, a pretrial detainee at Cleveland County Jail, suffered a brain infection and permanent incapacitation after an alleged untreated/misdiagnosed sinus infection while in custody. His mother, Sandra Valentine, is a co-plaintiff.
Plaintiffs sued Sheriff Joseph Lester in his official capacity under 42 U.S.C. § 1983, alleging deliberate indifference to Autry’s serious medical needs and a deficient policy/training that caused the harm.
Complaint alleges repeated communications from Autry and his mother to jail reception and medical staff about his traumatic brain injury (TBI) history and sinus infection, with delayed or inadequate treatment and an insufficient ER visit before emergency brain surgery.
Sheriff Lester moved to dismiss under Fed. R. Civ. P. 12(b)(6), arguing official-capacity claims require pleading an unconstitutional county policy or custom and that Valentine lacks a personal § 1983 claim.
The court applied Iqbal/Twombly plausibility standards and Tenth Circuit precedent requiring identification of specific actions, policies, or training deficiencies causally linked to the injury.
Court dismissed: (1) Count I (municipal liability for denial of medical care) for failure to plead a policy or custom causing the injury; (2) Count II (failure-to-train) for insufficient facts showing deliberate indifference or that lack of training was the moving force; and (3) Valentine’s individual § 1983 claim for lacking a personal constitutional violation. Leave to amend was denied.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an official-capacity § 1983 claim was pleaded against Sheriff/County based on denial of medical care	Autry/Valentine: sheriff was on actual notice via communications; jail’s failure to treat shows deliberate indifference	Lester: official-capacity claim is against the county and requires allegation of an unconstitutional policy or custom causing the injury	Dismissed — complaint lacks factual allegations identifying a deficient policy or causal link to county action
Whether failure-to-train/inadequate policy claim states § 1983 municipal liability	Plaintiffs: alleged poor communication and lack of training to convey serious medical needs; need for training obvious given prior incidents (argued in briefing)	Lester: no specific training deficiency pleaded; plaintiffs must show obvious need and that training deficiency was moving force	Dismissed — allegations too speculative; no pattern or obvious, specific deficiency showing deliberate indifference
Whether Valentine has an individual § 1983 claim for loss of companionship/substantive due process	Plaintiffs: Valentine alleges loss of familial companionship and asserts a substantive due process right	Lester: § 1983 requires violation of plaintiff’s own constitutional rights; she alleges only harms to her son	Dismissed — no factual or legal basis shown for Valentine’s independent substantive due process claim
Whether plaintiffs should get leave to amend to plead municipal liability	Plaintiffs: request leave and contend discovery is needed to plead policy/custom (incapacity of Autry cited)	Lester: scheduling deadlines passed; prior amendments failed; plaintiffs must meet Rule 8 to unlock discovery	Denied — plaintiffs failed to propose particular amendments, delayed, and amendments would be futile

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (pleading must state a plausible claim; disregard conclusory allegations)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for complaints)
Robbins v. Oklahoma, 519 F.3d 1242 (identify who did what to whom in § 1983 pleadings)
Martinez v. Beggs, 563 F.3d 1082 (suit against sheriff in official capacity equals suit against county)
Mocek v. City of Albuquerque, 813 F.3d 912 (municipal liability requires policy or custom causing injury)
Moss v. Kopp, 559 F.3d 1155 (same principle for county liability under § 1983)
City of Canton v. Harris, 489 U.S. 378 (municipal liability for failure to train where deliberate indifference is shown)
Connick v. Thompson, 563 U.S. 51 (pattern of violations ordinarily necessary to show deliberate indifference in failure-to-train claims)
Schneider v. City of Grand Junction Police Dep’t, 717 F.3d 760 (discusses municipal liability standards under Monell)
Porro v. Barnes, 624 F.3d 1322 (plaintiff must identify specific training deficiency closely related to injury)
Ghailani v. Sessions, 859 F.3d 1295 (pleading standard required to obtain discovery)
Pahls v. Thomas, 718 F.3d 1210 (plaintiff must identify actions by specific defendants to state § 1983 claim)