Craig v. Floyd County, Ga.
2011 U.S. App. LEXIS 12406
| 11th Cir. | 2011Background
- Craig, a pretrial detainee, was held at Floyd County Jail after a July 4, 2006 incident in Rome, Georgia.
- Georgia Correctional Health, LLC (GCH) provided health care services to detainees at the jail through private contractors.
- Craig underwent sixteen health evaluations by nine GCH employees over nine days before a CT scan revealed air, bleeding, and fractures in his head requiring neurological surgery.
- Hatfield, a GCH nurse practitioner, assessed Craig the morning after arrest and did not obtain Floyd Medical Center records or refer him to a physician initially.
- A CT scan on July 13, 2006 led to transfer to Floyd Medical Center and subsequently Grady Memorial Hospital for neurosurgery.
- Craig filed suit in June 2008 alleging GCH maintained a policy or custom of deliberate indifference to serious medical needs; the district court granted summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Craig proved a policy or custom of deliberate indifference | Craig argues a persistent custom caused his injury | GCH asserts only a single incident; no policy or widespread practice shown | No; single incident insufficient to establish policy or custom |
| Whether a single incident can establish a Monell policy | Craig relies on one major incident to show a custom | Single incident cannot prove policy; requires persistent practice | No; one incident cannot establish a policy or custom |
| Whether Craig's proposed practices (referral failure, reliance on clearances, cost-cutting) amount to a persistent custom | Practices were widespread and persistent | Evidence shows only isolated instances related to Craig; not persistent | No; insufficient evidence of widespread custom |
| Whether expert testimony on practices admissible where expert had no personal knowledge of Floyd County Jail | Dr. Graham based his opinion on jail-care experience | Dr. Graham lacked personal knowledge of the facility; opinion insufficient | No; reliance on experience at other jails cannot prove GCH custom |
Key Cases Cited
- Monell v. Dept. of Social Servs. of N.Y.C., 436 U.S. 658 (U.S. 1978) (local government liability requires a policy or custom)
- Bd. of Cnty. Comm'rs of Bryan Cnty. v. Brown, 520 U.S. 397 (U.S. 1997) (persistent or widespread practice; need for causation)
- City of Canton v. Harris, 489 U.S. 378 (U.S. 1989) (government liability requires a policy or custom; deliberate indifference)
- McDowell v. Brown, 392 F.3d 1283 (11th Cir. 2004) (isolated incident not enough for policy; multiple actors still insufficient)
- Tuttle v. Oklahoma City, 471 U.S. 808 (U.S. 1985) (single incident cannot impose liability under §1983)