Garressa Smith v. Dean Gransden, 553 F. App'x 173

Background

On Dec. 21, 2007, Officer Dean Gransden shot 17-year-old Kashon Smith twice after Smith reportedly charged at him with a knife and grill fork; Smith was handcuffed and left face-down in mulch at the scene.
Sergeant Jeffrey Frampton arrived shortly after (first supervisor), saw Smith conscious but bleeding, called for an ambulance, secured the scene, but did not turn Smith over, remove handcuffs, or administer first aid.
EMTs arrived about 10–15 minutes later; officers refused an EMT request to remove handcuffs; Smith was transported to hospital without a police officer accompanying the ambulance and without IV fluids; pronounced dead ~1 hour later; autopsy attributed death to gunshot wounds.
Plaintiff (Smith’s mother/estate) sued under 42 U.S.C. § 1983 alleging Frampton’s deliberate indifference to medical needs and municipal liability against the City of Camden; trial produced a jury verdict for Frampton and the district court granted judgment as a matter of law for Camden.
On appeal, the Third Circuit reviewed (1) denial of plaintiff’s Rule 50(b) motion/JNOV and motion for a new trial regarding Frampton, and (2) the district court’s Rule 50(a) grant for Camden.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Frampton was deliberately indifferent to Smith’s medical needs (Fourteenth Amendment)	Frampton knew Smith was injured and failed to provide or direct medical aid (not turning him, not removing handcuffs, not ordering first aid)	Frampton secured the scene, promptly called for ambulance, lacked medical training, and actions were reasonable under chaotic circumstances	Affirmed for Frampton — evidence insufficient to show subjective deliberate indifference; jury verdict stands
Whether Frampton is liable as a supervisor for others’ alleged failures	Frampton had actual knowledge/acquiescence and failed to supervise to ensure medical aid	Frampton did not direct or acquiesce in constitutional wrongdoing; he took steps to obtain medical care	Affirmed for Frampton — insufficient evidence of personal involvement or acquiescence
Whether City of Camden is liable under Monell for an unwritten policy/custom causing violation	Camden’s policies/customs caused officers to be deliberately indifferent to arrestee medical needs	No underlying constitutional violation by officers; no municipal policy produced causal constitutional injury	Affirmed for Camden — no derivative municipal liability where no officer violation was proven
Whether district court erred in granting JMOL for Camden or denying new trial/JNOV for Frampton	JMOL for Camden improper; jury’s verdict against Frampton should be set aside	District court's rulings supported by record and controlling standards for sufficiency and weight of evidence	Affirmed: district court did not err or abuse discretion

Key Cases Cited

Gomez v. Toledo, 446 U.S. 635 (1980) (§ 1983 elements require action under color of law depriving federal rights)
City of Revere v. Mass. Gen. Hosp., 463 U.S. 239 (1983) (deliberate indifference to medical needs of detainees violates Due Process)
Natale v. Camden Cnty. Corr. Facility, 318 F.3d 575 (3d Cir. 2003) (elements and subjective deliberate indifference standard for detainee medical claims)
Groman v. Twp. of Manalapan, 47 F.3d 628 (3d Cir. 1995) (deliberate indifference principles for law-enforcement contexts)
Miller v. City of Phila., 174 F.3d 368 (3d Cir. 1999) (causation requirement between indifference and injury)
Nicini v. Morra, 212 F.3d 798 (3d Cir. 2000) (deliberate indifference as a subjective recklessness standard)
McKenna v. City of Phila., 582 F.3d 447 (3d Cir. 2009) (supervisory liability requires personal involvement/knowledge and acquiescence)
Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (1978) (municipal liability requires a policy or custom causing a constitutional violation)
Mulholland v. Gov’t Cnty. of Berks, Pa., 706 F.3d 227 (3d Cir. 2013) (no municipal liability where no officer committed constitutional violation)
City of L.A. v. Heller, 475 U.S. 796 (1986) (a city cannot be liable where the officer inflicted no constitutional injury)
Acumed LLC v. Advanced Surgical Servs., Inc., 561 F.3d 199 (3d Cir. 2009) (standard for JMOL/JNOV deficiency of evidence)
Pryer v. C.O. 3 Slavic, 251 F.3d 448 (3d Cir. 2001) (standard for new trial when verdict is against the weight of evidence)