Duvall v. DALLAS COUNTY, TEX.
631 F.3d 203
5th Cir.2011Background
- Duvall, a pre-trial detainee, stayed in Dallas County Jail from December 11–26, 2003 and contracted MRSA there.
- Duvall alleged a due process violation under the Fourteenth Amendment based on an unconstitutional condition of confinement.
- A jury found in Duvall's favor on the §1983 claim, and the County timely appealed.
- The County challenged jury instructions, the sufficiency of the evidence, and Monell liability.
- The district court instructed under Hare and Monell principles; the evidence showed a pervasive MRSA problem and inadequate controls.
- The court affirmed, holding the district court did not abuse its discretion and the evidence supported the jury's findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the jury instructions and JMOL denial were proper | Duvall | Dallas County | No abuse of discretion; instructions were proper |
| Whether the evidence supports a Fourteenth Amendment due-process violation from conditions of confinement | Duvall showed a pervasive, non-relationship to a legitimate objective and cumulative harm from MRSA | County argued the conditions were not unconstitutional or related to a policy | Evidence supported a constitutional violation from an unconstitutional condition |
| Whether the evidence supports municipal liability under Monell | Duvall proved a custom or policy with deliberate indifference | County contested the existence of an official policy or widespread custom | Yes; jury properly found a policy or custom with deliberate indifference |
Key Cases Cited
- Bell v. Wolfish, 441 U.S. 520 (U.S. 1979) (conditions not punishment if related to legitimate objective)
- Hare v. City of Corinth, 74 F.3d 633 (5th Cir. 1996) (en banc; deliberate indifference standard in conditions cases)
- Monell v. Dep’t of Soc. Serv. of City of New York, 436 U.S. 658 (U.S. 1978) (municipal liability for official policy or custom)
- Shepherd v. Dallas County, 591 F.3d 445 (5th Cir. 2009) (conditions of confinement; evidence of policy or custom; deference to jury)
- Brumfield v. Hollins, 551 F.3d 322 (5th Cir. 2008) (deliberate indifference standard for Monell and related claims)