Billy W. Reid v. Brian Streit, 697 F. App'x 968

Reid was pursued, tasered, and fell, worsening a preexisting right-hand injury; deputies arrested and took him to a substation where he repeatedly complained of severe hand pain.
Paramedics who examined Reid at the substation said his injury was too severe for them and recommended immediate hospital transport.
Sergeant Streit instructed Deputy Webber not to take Reid to the hospital and to wait so Streit could interview Reid; the interview began ~4.5 hours after apprehension and Reid was told he would not get medical care until he gave a “satisfactory statement.”
After the interview Streit placed Reid under arrest; Reid later left the holding cell, sought but was initially denied ER care for lack of insurance, and after later arrest received surgery for a boxer’s fracture and alleges permanent impairment.
Reid sued under 42 U.S.C. § 1983 for deliberate indifference to serious medical needs (Fourteenth Amendment), seeking declaratory, injunctive, and monetary relief against the officers in official and individual capacities.
District court denied officers’ summary judgment based on sovereign/qualified immunity; Eleventh Circuit reviewed and partially affirmed/reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to seek injunctive/declaratory relief against officers in official capacities	Reid will be affected by future conduct and thus has standing for prospective relief	No evidence Reid faces a future risk from these officers	No standing for equitable relief in official capacities; claims dismissed as to prospective relief against officers in official capacity
Qualified immunity for monetary claims against officers in individual capacities	Officers delayed and refused medical care knowing Reid had a serious hand injury, so they violated clearly established law	Officers entitled to qualified immunity; no constitutional violation or clearly established law appl.	Denied qualified immunity at summary judgment stage; factual dispute permits jury to find deliberate indifference
Duty to treat injury sustained (or worsened) during apprehension	Officers had duty to provide care for injury known/obvious and worsened by fall during apprehension	Injury preexisted custody and fall did not worsen it, so no duty/violation	Officers had duty; factual disputes (fall worsened injury) must be resolved by jury
Causation / link between delay and harm	Delay caused unnecessary pain and possibly contributed to worse outcome; thus causation exists	No evidence delay caused need for surgery, so no causal link	Even if delay didn’t cause surgery, jury could find delay caused unnecessary suffering; causation dispute precludes summary judgment

Feliciano v. City of Miami Beach, 707 F.3d 1244 (11th Cir. 2013) (standard of review for denial of summary judgment based on immunity)
Pellitteri v. Prine, 776 F.3d 777 (11th Cir. 2015) (qualified immunity summary judgment standard)
Revere v. Massachusetts General Hospital, 463 U.S. 239 (U.S. 1983) (government must provide medical care to persons injured while being apprehended)
Brown v. Hughes, 894 F.2d 1533 (11th Cir. 1990) (unexplained hours-long delay in treating serious injury permits inference of deliberate indifference)
McElligott v. Foley, 182 F.3d 1248 (11th Cir. 1999) (elements of deliberate indifference: subjective knowledge, disregard, more than negligence)
Harris v. Coweta County, 21 F.3d 388 (11th Cir. 1994) (length of tolerable delay depends on need and reason; hours-long delay for broken bones may constitute deliberate indifference)
Lee v. Ferraro, 284 F.3d 1188 (11th Cir. 2002) (purpose of qualified immunity to protect officials except the plainly incompetent)
Mobley v. Palm Beach County Sheriff’s Department, 783 F.3d 1347 (11th Cir. 2015) (first step: official acted within discretionary authority when asserting qualified immunity)
Mitchell v. Forsyth, 472 U.S. 511 (U.S. 1985) (interlocutory appeal permitted from denial of immunity)