Jana Childers v. San Saba County
714 F. App'x 384
5th Cir.2018Background
- Jesse Childers, with known heart trouble, was arrested and detained in San Saba County Jail for ~16 hours and missed one dose of metoprolol while in custody.
- At intake he acknowledged past heart problems; he told Sheriff Allen Brown he needed his heart medication but did not have it with him.
- Jail trustee overheard the request; Jesse’s wife brought some medications to the jail, but not metoprolol.
- Overnight Jesse experienced chest pain, palpitations, shortness of breath, and nausea; jail staff gave muscle relaxers and ibuprofen from family-supplied meds.
- On release the next morning EMS was called but Jesse refused transport; he later was diagnosed with heart failure and died 25 days after incarceration.
- Jana Childers sued under 42 U.S.C. § 1983 alleging Fourteenth Amendment deliberate indifference by Sheriff Brown; district court granted summary judgment for Brown and San Saba County, and Jana appealed as to Brown individually.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Brown’s refusal to provide metoprolol violated pretrial detainee due-process rights | Childers: denying the requested heart medication constituted deliberate indifference causing substantial harm | Brown: missing one dose did not cause substantial harm and therefore cannot show constitutional violation | Court: No — plaintiff produced no evidence that a single missed dose caused harm; claim fails |
| Whether Brown’s response to Jesse’s symptoms (chest pain, etc.) was deliberately indifferent | Childers: Brown ignored serious symptoms and failed to provide adequate medical care | Brown: staff provided family medication and called EMS; no evidence he refused, ignored, or intentionally mistreated Jesse | Court: No — actions (meds provided, EMS called) fall short of wanton disregard required for deliberate indifference |
| Qualified immunity for Brown | Childers: Brown violated clearly established rights by denying meds/medical care | Brown: even if constitutional duty existed, no clearly established violation shown; summary judgment proper | Court: Affirmed — no clearly established constitutional violation shown |
| Evidentiary disputes over affidavit/hearsay | Childers: affidavit supports failure-to-act claim | Brown: other records (med log, staff affidavits) contradict affidavit; district court excluded portions as hearsay | Court: Did not need to resolve hearsay exclusion — ruling would be same even if affidavit fully considered |
Key Cases Cited
- Doe v. Robertson, 751 F.3d 383 (5th Cir. 2014) (qualified immunity burden and standard)
- Alderson v. Concordia Par. Corr. Facility, 848 F.3d 415 (5th Cir. 2017) (episodic acts or omissions standard for pretrial detainees)
- Mendoza v. Lynaugh, 989 F.2d 191 (5th Cir. 1993) (delay in medical care requires deliberate indifference causing substantial harm)
- Easter v. Powell, 467 F.3d 459 (5th Cir. 2006) (contrast where officer ignored chest pain and provided no treatment)
- Domino v. Texas Dep’t of Criminal Justice, 239 F.3d 752 (5th Cir. 2001) (examples of conduct showing wanton disregard)
- Gobert v. Caldwell, 463 F.3d 339 (5th Cir. 2006) (negligence insufficient to show deliberate indifference)