Estate of Laura Allison v. Wood County, Tex, 524 F. App'x 963

Appellants appealed a district court denial of summary judgment on the defense of qualified immunity in a §1983 death-and-medical-care case arising from Laura Allison’s incarceration at Wood County Jail.
Decedent Allison was arrested for DUI in February 2007 and arrived at the VIP program-related process and jail in March 2009, where officers and jail staff interacted with her while she appeared intoxicated and reported taking prescribed meds.
Jail staff monitored Allison periodically after booking, but the record shows conflicting testimony about her medical distress and whether further medical aid was pursued or available on site at night.
Allison’s death occurred after the jail period, with autopsy attributing death to acute ethanol intoxication and toxicology showing ethanol and benzodiazepines present.
Appellees asserted policy and training deficiencies at the Jail, including lack of on-site medical staff at night and limited CPR training, while Appellants argued adequate training and a permissive approach to medical assistance.
The district court denied qualified immunity; the Fifth Circuit reversed and remanded, holding jailers were entitled to qualified immunity and Sheriff Wansley also entitled, and directing further proceedings consistent with the opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the jailers violate due process by deliberate indifference to medical needs?	Allison’s death shows deliberate indifference due to intoxication and medication factors.	Jailers monitored and attempted to assist; no subjective intent to harm.	No; jailers entitled to qualified immunity.
Was there subjective knowledge of a substantial risk and deliberate indifference by the jailers?	Jailers knew Allison was highly intoxicated and on medication, creating substantial risk.	Monitoring and attempts to awaken her show lack of intent to harm.	Not shown; no evidence of subjective intent to harm; qualified immunity applies.
Is Sheriff Wansley liable for supervisory deficiency and training under §1983?	Inadequate training and policy structure violated rights.	There is no basis for supervisory deliberate indifference; training policies exist.	Sheriff Wansley entitled to qualified immunity.
Should the district court’s denial of qualified immunity be affirmed on the basis of the record evidence?	Disputed facts show lack of objective reasonableness.	Even disputed facts do not defeat objective reasonableness; immunity applies.	Yes; grant of qualified immunity affirmed on the record; remanded for further proceedings.

Pearson v. Callahan, 555 U.S. 223 (2009) (two-prong qualified immunity framework; flexible sequencing)
Anderson v. Creighton, 483 U.S. 635 (1987) (objective reasonableness standard for qualified immunity)
Thompson v. Upshur Cnty., Tex., 245 F.3d 447 (5th Cir. 2001) (requirement of pattern or obvious training failure for supervisory liability)
Hare v. City of Corinth, 74 F.3d 633 (5th Cir. 1996) (deliberate indifference requires more than negligent response)
Brown v. Callahan, 623 F.3d 249 (5th Cir. 2010) (objective reasonableness; questions of law for court)
Gobert v. Caldwell, 463 F.3d 339 (5th Cir. 2006) (access to interlocutory appeal of qualified immunity; materiality standard)
Manis v. Lawson, 585 F.3d 839 (5th Cir. 2009) (scope of appellate review for qualified immunity; materiality only)
Tamez v. Manthey, 589 F.3d 764 (5th Cir. 2009) (subjective knowledge and response standard for deliberate indifference)
Scott v. Moore, 114 F.3d 51 (5th Cir. 1997) (episodic acts/omissions framework for §1983 claims)