Brown Ex Rel. Estate of Brown v. Bolin, 500 F. App'x 309

Jason Ray Brown, a 26-year-old pretrial detainee, died from a massive gastrointestinal hemorrhage at Wichita County Jail.
Brown, arrested July 22, 2004, had chronic medical conditions and requested continuous care; jail records showed long-standing prescription medications not picked up.
Nurse George attempted to obtain medication orders; jail physician Dr. Bolin did not engage until after standing orders were invoked and Brown’s condition deteriorated.
Brown vomited blood July 23; officers and nurse Krajca administered antacid and a phosphorized nausea medication under standing orders; Brown became incoherent by early July 24.
Krajca moved Brown to medical solitary and administered suppositories; Brown died later that day; autopsy listed massive GI hemorrhage as cause.
District court granted summary judgment for Wichita County and Dr. Bolin (relying on Callahan); this court previously held Sheriff Callahan entitled to qualified immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brown’s claim is episodic acts or a confinement condition	Browns allege episodic indifference by specific actors under deficient policies.	Case should be treated as episodic acts; no systemic failure shown.	Episodic acts case; not a systemic condition of confinement.
Dr. Bolin's qualified immunity for episodic acts	Bolin knew of and disregarded substantial risk via his policy of nighttime inaccessibility.	No evidence Bolin had actual knowledge of a substantial risk; policy not shown to be the moving force.	No genuine fact issue; Bolin entitled to qualified immunity.
Wichita County's qualified immunity for municipal liability	County policy or custom caused deliberate indifference to inmates’ medical needs.	No evidence of deliberate indifference in promulgating unconstitutional policy; no moving force.	County entitled to qualified immunity; no policy or custom shown to cause violation.
Supervisory liability standards applied to Dr. Bolin’s conduct	Supervisory policy created risk; failure to train or supervise contributed to violation.	No evidence of a failure to train or supervise that caused Brown’s death; isolated incident cannot support liability.	No supervisor liability established against Bolin at summary judgment stage.

Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for inmates)
Hare v. City of Corinth, Miss., 74 F.3d 633 (5th Cir.1996) (due process rights of pretrial detainees; episodic acts standard)
Shepherd v. Dallas County, 591 F.3d 445 (5th Cir.2009) (systemic failure evidence required for confinement-condition claim)
Duvall v. Dallas County, 631 F.3d 203 (5th Cir.2011) (evidence of systemic infection control; not present here)
Scott v. Moore, 114 F.3d 51 (5th Cir.1997) (difference between policy and actor-specific acts analysis)
Thompkins v. Belt, 828 F.2d 304 (5th Cir.1987) (definition of official policy and deliberate indifference standards)
Cozzo v. Tangipahoa Parish Council-Pres. Gov't, 279 F.3d 273 (5th Cir.2002) (supervisory liability requiring policy or custom causing violation)
Piotrowski v. City of Houston, 237 F.3d 567 (5th Cir.2001) (elements of municipal liability under §1983)
McElligott v. Foley, 182 F.3d 1248 (11th Cir.1999) (supervisor policy findings when nurses' actions create risk)
Clark-Murphy v. Foreback, 439 F.3d 280 (6th Cir.2006) (triable issue for deliberate indifference when risk is obvious)
Brown v. Callahan, 623 F.3d 249 (5th Cir.2010) (Sheriff entitled to qualified immunity; context for supervisory liability)