Jeffery Mays v. Ronald Sprinkle
992 F.3d 295
| 4th Cir. | 2021Background
- David Mays was found extremely intoxicated in his pickup (911 call reported alcohol plus prescription narcotics); officers observed slurred speech, lethargy, and pill bottles in his truck with missing capsules.
- Deputies arrested Mays for public intoxication, escorted him through a magistrate’s hearing, and placed him in a jail cell; he received no medical evaluation or treatment from arrest through booking.
- Jail checks hours later found Mays unconscious; deputies attempted CPR, EMS arrived, but Mays died of combined drug intoxication (hydrocodone, gabapentin, citalopram, alprazolam).
- Mays’s estate sued under 42 U.S.C. § 1983 alleging Fourteenth Amendment deliberate indifference to serious medical needs (Count II); district court dismissed Count II and granted qualified immunity to officers.
- The Fourth Circuit reversed, holding the amended complaint plausibly alleged an objectively serious medical need and that officers had subjective knowledge of that need and the excessive risk created by inaction, so dismissal and qualified-immunity relief were improper at the 12(b)(6) stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the complaint plausibly alleges deliberate indifference to a serious medical need (objective element) | Mays: 911 caller reported extreme intoxication and need for medical care; officers observed severe lethargy, inability to stand/sit, and pill bottles — overdose obvious to a layperson | Officers: facts resemble routine intoxication cases (e.g., Grayson, Burnette); no physician diagnosis, no observed ingestion, no evidence officers knew dose or specific risk | Court: Allegations plausibly show an objectively serious condition (overdose risk) and survive 12(b)(6) when drawing reasonable inferences for plaintiff |
| Whether officers had the requisite subjective knowledge of the serious condition and excessive risk | Mays: officers knew of the 911 call, observed extreme impairment, and saw prescription bottles; these facts permit inference they knew the risk | Officers: they did not know exact drugs/doses or that Mays consumed a lethal amount; similar prior encounter suggested he might just ‘sleep it off’ | Court: Complaint plausibly alleges that officers subjectively knew of the serious medical need and disregarded the risk; factual disputes reserved for later stages |
| Whether Kingsley v. Hendrickson changed the deliberate-indifference standard for pretrial detainees (objective vs. subjective) and whether that affects qualified immunity | Mays: argues post-Kingsley standard should be purely objective for pretrial detainees | Officers: argue traditional subjective standard applies; qualified immunity protects them | Court: Did not resolve whether Kingsley altered the standard because, under the pre-Kingsley (subjective) framework, Mays’s allegations still clear the qualified-immunity threshold; qualified immunity therefore denied at motion-to-dismiss stage |
Key Cases Cited
- Kingsley v. Hendrickson, 576 U.S. 389 (2015) (addressing objective standard for excessive-force claims by pretrial detainees)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate indifference to serious medical needs)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires subjective knowledge of risk)
- Ashcroft v. al‑Kidd, 563 U.S. 731 (2011) (qualified immunity framework requires clearly established right)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard; legal conclusions insufficient)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Grayson v. Peed, 195 F.3d 692 (4th Cir. 1999) (summary judgment for officers where decedent’s symptoms did not objectively indicate serious medical need)
- Burnette v. Taylor, 533 F.3d 1325 (11th Cir. 2008) (summary judgment where intoxication signs did not make serious condition obvious)
- Jackson v. Lightsey, 775 F.3d 170 (4th Cir. 2014) (deliberate-indifference requires objective and subjective elements)
- Scinto v. Stansberry, 841 F.3d 219 (4th Cir. 2016) (objective seriousness defined: physician diagnosis or obviousness to layperson)
- Darnell v. Pineiro, 849 F.3d 17 (2d Cir. 2017) (post‑Kingsley discussion applying objective-reasonableness test to detainee medical claims)
- Doe 4 ex rel. Lopez v. Shenandoah Valley Juvenile Ctr. Comm’n, 985 F.3d 327 (4th Cir. 2021) (reiterating objective-and-subjective formulation for pretrial detainee medical claims in this Circuit)