Cooper v. City of Cottage Grove, 6:13-cv-00551

Background

Nathan S. Cooper was jailed in Cottage Grove Municipal Jail from April 26–May 5, 2012; he exhibited prolonged vomiting, diarrhea, weight loss (~176–180 lbs on April 27 to ~120 lbs at death), and withdrawal symptoms.
EMTs evaluated him multiple times (April 27 and May 1), diagnosed withdrawal, advised hydration and hospital evaluation if symptoms persisted; Cooper declined transport on at least one occasion.
Officers provided Gatorade but did not monitor fluid intake or log vital signs; Cooper repeatedly requested medical attention and at least once reported vomiting blood but that was not communicated or acted upon.
Jail policy options for ill inmates were: call EMTs, take to hospital, or grant medical furlough; no medical staff or full-time corrections-trained monitor was assigned to the jail. Budget was minimal and the City did not require follow-up after furloughs.
On May 5, 2012 Cooper was found dead; autopsy found aspiration pneumonia and advanced bacterial lung infection consistent with complications of opiate withdrawal, dehydration, vomiting, and diarrhea.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether individual officers were deliberately indifferent to a serious medical need in violation of the Eighth Amendment	Cooper’s estate: officers knew of severe withdrawal, vomiting (including vomiting blood), dehydration, and dramatic weight loss, yet failed to provide or obtain medical care	Defendants: believed Cooper had nonfatal withdrawal symptoms and lacked knowledge of a serious, life‑threatening condition; actions amounted to nonculpable medical judgment or negligence	Denied summary judgment — jury could find facts showing officers knew of and disregarded a substantial risk; material issues for trial
Whether the City is liable under § 1983 for customs, policies, or omissions	Estate: City’s understaffing, tiny jail budget, lack of medical monitoring/logging, and reliance on furloughs/EMTs reflect deliberate indifference and were moving force behind constitutional violation	City: municipal liability requires a constitutional violation by an employee; absent individual liability, City cannot be liable	Denied summary judgment — jury could infer municipal deliberate indifference from policies, omissions, and cumulative practices
Whether mere negligence suffices for constitutional liability	Estate: argues conduct went beyond negligence to deliberate indifference given known risks and failures to act/communicate	Defendants: point to negligence or medical judgment mistakes, not Eighth Amendment culpability	Court: clarified that mere negligence is insufficient but found record could support deliberate indifference, so factual resolution required at trial
Whether summary judgment appropriate on the record	Estate: material factual disputes exist about what officers knew and did, requiring trial	Defendants: asserted absence of genuine dispute as to material facts	Court: summary judgment denied because reasonable jury could resolve disputed evidence for plaintiff

Key Cases Cited

Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference to serious medical needs)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference requires awareness of substantial risk and drawing the inference)
Jett v. Penner, 439 F.3d 1091 (definition of serious medical need / Eighth Amendment context)
McGuckin v. Smith, 974 F.2d 1050 (treatment of serious medical need in prison context)
Toguchi v. Chung, 391 F.3d 1051 (mere negligence in diagnosis/treatment does not violate Eighth Amendment)
Gibson v. County of Washoe, 290 F.3d 1175 (municipal liability and standards for showing customs/policies and deliberate indifference)
Speer v. Glover, 276 F.3d 980 (combined actions of multiple employees may support municipal liability)
Canton v. Harris, 489 U.S. 378 (municipal liability for failure to train or for customs amounting to deliberate indifference)