Bond v. Oklahoma County Criminal Justice Authority, 5:23-cv-00005

Brad Lane, a pretrial detainee with a non-violent criminal history, was murdered by his cellmate, Shaquile Brown, in the Oklahoma County Detention Center's medical floor.
Brown was detained for violent offenses and required frequent medical care, leading to their placement together.
On the medical floor, only one officer was present at the time of the attack, contrary to staffing requirements; distress calls from inmates went unanswered due to systemic practices routing calls to an unmanned nurse’s station.
Lane was assaulted over 30-45 minutes, repeatedly calling for help; another inmate attempted to alert staff but was unsuccessful due to inadequate response systems.
Plaintiff alleges that longstanding understaffing and monitoring failures, widely recognized within the facility and by external inspections, led to Lane’s death, and seeks municipal liability under § 1983 against the Oklahoma County Criminal Justice Authority (OCCJA) and the Board of County Commissioners.
Defendants moved for summary judgment. The court denied the motion as to OCCJA, finding disputed material facts, but granted it as to the Board due to insufficient evidence of its direct policy or knowledge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Underlying Constitutional Violation	Systemic understaffing and lack of monitoring created	No specific risk or threat to Lane; no particular vulnerability	Sufficient evidence of systemic failure
	conditions of substantial risk, deliberate indifference.	or history of violence by Brown toward Lane.	for a reasonable jury to find a violation.
OCCJA Municipal Liability (Policy or Custom)	OCCJA maintained a policy or custom of severe understaffing,	No substantive argument; did not dispute existence of custom.	Disputed facts suffice to go to a jury.
	failed to remedy known dangers, ignored staff warnings.
Causation	Inadequate staffing and failed monitoring directly allowed	Incident unpredictable and spontaneous; no causal link.	Jury could find causation between custom
	Lane’s prolonged fatal beating to occur.		of understaffing, lack of checks, & death.
Deliberate Indifference	OCCJA had notice of the risks, ignored warnings and memos	Williams tried to hire more staff (undated efforts);	A jury could find deliberate indifference
	about dangerous conditions; did not take action.	OCCJA not deliberately indifferent.	to obvious risks, precluding summary judgment.
Board of County Commissioners' Liability	Board should be liable for same reasons as OCCJA.	Board had no control over OCCJA policies; no evidence	Insufficient evidence against the Board;
		Board caused violation.	summary judgment granted to the Board.

Monell v. Dep’t of Social Servs. of City of New York, 436 U.S. 658 (1978) (establishes that municipal liability under § 1983 requires a policy or custom as the moving force behind the violation)
Farmer v. Brennan, 511 U.S. 825 (1994) (prison officials must protect prisoners from substantial risks of serious harm; deliberate indifference standard)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard focusing on material fact disputes)
Bd. of Cnty. Comm’rs of Bryan Cnty., Okla. v. Brown, 520 U.S. 397 (1997) (municipal liability requires causation; challenged policy must be closely related to injury)
Tafoya v. Salazar, 516 F.3d 912 (10th Cir. 2008) (deliberate indifference does not require knowledge of individual risk; systemic risks suffice)
Lucas v. Turn Key Health Clinics, LLC, 58 F.4th 1127 (10th Cir. 2023) (systemic failure can constitute an underlying constitutional violation for municipal liability)