Harris v. Pearl River County, Miss, 1:23-cv-00230

Plaintiff, Timothy Franklin Harris, filed a pro se complaint under 42 U.S.C. § 1983, alleging inadequate medical care during his pretrial detention at the Pearl River County Jail in Mississippi from September 2022 to March 2023.
Harris claimed persistent and worsening abdominal and back pain, including vomiting, diarrhea, and bleeding, believing his medical complaints were overlooked and not properly addressed due to his family history of stomach cancer.
Pearl River County was the sole defendant; Harris did not allege individual wrongdoing but claimed County liability based on alleged systemic deficiencies.
The County moved for summary judgment, arguing no constitutional violation or basis for municipal liability; Harris did not respond.
The Magistrate Judge recommended summary judgment for the County, finding no sufficient evidence of constitutional deprivation or a policy causing harm; Plaintiff filed no objections.
The District Court adopted the recommendation, granted summary judgment for the County, and dismissed Harris's claims with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there deliberate indifference to Harris’s serious medical needs?	Harris alleged medical staff ignored worsening symptoms and failed to diagnose/treat his condition.	County argued there was no evidence of deliberate indifference or constitutional violation.	No deliberate indifference; no evidence supporting a constitutional violation.
Can Pearl River County be held liable as a municipality under § 1983?	County practices/policies caused inadequate care (asserted generally).	No evidence of a specific policy or custom causing harm; no municipal liability shown.	No municipal liability; claim requires a policy/custom as moving force behind violation, which was not shown.
Is summary judgment appropriate given the record?	(No response filed to summary judgment motion.)	No genuine dispute of material fact; entitled to judgment as matter of law.	Summary judgment granted; claims dismissed with prejudice.
Was the Magistrate Judge’s Report and Recommendation clearly erroneous or contrary to law?	No objection filed.	Report is correct and should be adopted.	Recommendation adopted in full; court found no error.

Ford v. Anderson Cnty., 102 F.4th 292 (5th Cir. 2024) (explains the standard for deliberate indifference and municipal liability for inadequate medical care claims under § 1983)
Cope v. Cogdill, 3 F.4th 198 (5th Cir. 2021) (sets forth constitutional standards for pretrial detainee medical care claims)
United States v. Wilson, 864 F.2d 1219 (5th Cir. 1989) (describes standard of review for unobjected-to magistrate judge recommendations)
Little v. Liquid Air Corp., 37 F.3d 1069 (5th Cir. 1994) (en banc) (outlines burden-shifting at summary judgment stage)