Cady Ex Rel. Estate of Galambos v. Walsh
2014 U.S. App. LEXIS 10416
| 1st Cir. | 2014Background
- Cady sued Corizon, Inc. employees Trueworthy, Walsh, and Williams under 42 U.S.C. § 1983 for deliberate indifference to Galambos's serious medical needs while a pretrial detainee at CCJ.
- Corizon contracted to provide healthcare at CCJ; employees administered and supervised psychiatric treatment and decisions about medication and care.
- District court assumed Corizon defendants were within a qualified immunity category and denied summary judgment based on disputed material facts.
- Magistrate Judge found genuine issues of fact as to deliberate indifference, delaying the immunity analysis.
- The First Circuit dismissed the appeal for lack of appellate jurisdiction under Johnson v. Jones, holding the denial rested on disputed facts rather than pure legal questions.
- The opinion proceeds to address the Johnson separability issue and concludes the appeal cannot be heard on an interlocutory basis due to fact-bound questions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the appeal is reviewable on an interlocutory basis. | Cady argues Johnson v. Jones allows immediate review. | Defendants contend jurisdiction is limited when denial turns on disputed facts. | No jurisdiction; Johnson controls and facts prevent review. |
Key Cases Cited
- Johnson v. Jones, 515 U.S. 304 (1995) (limits interlocutory review of qualified immunity when based on disputed facts)
- Mlodzinski v. Lewis, 648 F.3d 24 (2011) (fact-bound, not reviewable on interlocutory appeal)
- Stella v. Kelley, 63 F.3d 71 (1995) (permits limited interlocutory review when the issue is legal, not fact-based)
- Tang v. Rhode Island, Dept. of Elderly Affairs, 120 F.3d 325 (1997) ( Johnson guidance on separability and factual disputes)
- Carter v. State of Rhode Island, 68 F.3d 9 (1995) (illustrates separation of fact-based and legal questions in immunity analyses)