Borchgrevink v. Harris County, Texas, 4:23-cv-03198

The civil rights case concerns the death of Matthew Shelton, a pretrial detainee at Harris County Jail, due to alleged deliberate indifference to his serious medical needs by multiple Detention Officers.
Plaintiffs, led by Sarah Borchgrevink as the administrator of Shelton's estate, bring claims under 42 U.S.C. § 1983 for violations of Shelton’s constitutional rights (Fourteenth Amendment).
Plaintiffs allege that Detention Officers ignored medical complaints, failed to act on nurse instructions to take Shelton to the clinic, falsified records, and did not properly monitor Shelton despite clear signs of a medical emergency.
Defendants (Detention Officers) moved to dismiss based on qualified immunity, arguing that their conduct did not violate clearly established law, and asserted failure of the pleadings to state a cognizable claim.
The Court previously outlined the background in an earlier order and considered the officers' conduct individually in relation to qualified immunity and sufficiency of factual pleadings.
No challenge to the procedural standing of Borchgrevink as estate administrator succeeded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Violation of Fourteenth Amendment rights	Detention Officers were deliberately indifferent to Shelton's medical needs	Officers did not act with deliberate indifference or violated law	Plaintiffs sufficiently pled deliberate indifference to serious needs
2. Qualified Immunity	Officers' conduct violated clearly established constitutional rights	Conduct did not violate clearly established law; immunity applies	Qualified immunity defense denied for all Detention Officers
3. Sufficiency of Pleadings (Rule 12(b)(6))	Complaint states a plausible claim for relief with specific facts	Allegations are insufficiently specific or inconsistent	Plaintiffs’ pleadings meet specificity requirements; motions to dismiss denied
4. Standing of Estate Administrator	Borchgrevink has standing as estate administrator	No standing to bring these claims	Borchgrevink has standing; motion to dismiss for lack of standing denied

Kisela v. Hughes, 138 S. Ct. 1148 (qualified immunity protects officials unless they violate clearly established law)
District of Columbia v. Wesby, 138 S. Ct. 577 (two-prong qualified immunity analysis—constitutional violation and clearly established law)
Ashcroft v. al-Kidd, 563 U.S. 731 (setting forth qualified immunity standard)
Easter v. Powell, 467 F.3d 459 (deliberate indifference to serious medical needs by jail officials is actionable under § 1983)
Sims v. Griffin, 35 F.4th 945 (officers liable for constitutional violation where they ignored a prisoner’s known serious medical emergency)
Hare v. City of Corinth, 74 F.3d 633 (Fourteenth Amendment standard for pretrial detainee claims)
Gobert v. Caldwell, 463 F.3d 339 (serious medical need is one for which treatment is recommended or obviously required)
Brown v. Callahan, 623 F.3d 249 (burden on plaintiff to defeat qualified immunity)
Carter v. Reach, 399 F. App’x 941 (deliberate indifference actionable under § 1983 for detainee medical needs)