Jaclyn Currie v. Jogendra Chhabra
2013 U.S. App. LEXIS 17545
| 7th Cir. | 2013Background
- Okoro died in a Williamson County jail from diabetic ketoacidosis after a period of detention without a Gerstein hearing.
- Health Professionals, Ltd. provided contracted medical care to arrestees/inmates at the jail, including Okoro; doctors Chhabra and Reynolds treated him.
- Currie, as administrator of Okoro’s estate, sued for federal constitutional and state-law claims arising from medical care provided during detention.
- The district court later allowed a Fourth Amendment framework for the medical-care claims, and Currie amended the complaint accordingly; the defendants challenged via a belated qualified-immunity motion.
- Chhabra and Reynolds sought interlocutory review of the denial of qualified immunity; the district court denied relief, and the Seventh Circuit addressed the appeal.
- The court ultimately affirmed the district court’s denial of qualified immunity to Chhabra and Reynolds, and remanded for further proceedings consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Fourth Amendment governs medical care for arrestees pre-Gerstein hearing. | Currie argues Fourth Amendment governs the medical-care claims. | Chhabra/Reynolds contend Fourth Amendment does not apply to private medical providers under contract. | Fourth Amendment governs; standard is objective reasonableness. |
| Whether private medical providers can raise qualified immunity in these circumstances. | Currie contends immunity should apply only where law permits. | Defendants contend immunity may apply to private providers. | Immunity defense not applicable; even if available, not warranted here. |
| Whether the district court properly entertained belated qualified-immunity arguments without jurisdictional flaw. | Currie argues lack of timely, proper presentation undermines jurisdiction. | Defendants contend district court acted within discretion in considering belated defense. | No jurisdiction problem; district court may consider belated qualified-immunity assertion. |
| Whether the defendants violated the Fourth Amendment by providing medically deficient care to an arrestee. | Okoro’s care was deliberately indifferent and caused death. | Defendants argue care was reasonable under the circumstances. | Record supports a Fourth Amendment claim; standard is objective reasonableness. |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (1989) (establishes reasonableness standard for excessive force; cited for constitutional standards context)
- Riverside County v. McLaughlin, 500 U.S. 44 (1991) (requires prompt probable cause determination; Gerstein hearing relevance)
- Ortiz v. City of Chicago, 656 F.3d 523 (2011) (applies Fourth Amendment medical-care standard to arrestees pre-Gerstein hearing)
- Williams v. Rodriguez, 509 F.3d 392 (2007) (applies Fourth Amendment medical-care standard to arrestees)