Jimmy Letterman v. Jerry Farnsworth
2015 U.S. App. LEXIS 10087
| 8th Cir. | 2015Background
- Letterman placed on suicide watch after transfer to Missouri Western Reception; placed in padded cell in TCU, with four-times-per-hour in-person checks required.
- Lammers failed to perform in-person checks, instead viewing Danial by monitor, and did not open the cell after Danial’s head injuries were observed.
- Danial fell and injured himself in the padded cell; medical personnel repeatedly requested opening the cell for vitals, but guards did not respond.
- Gastineau and Nurse Hook attempted to wake and check Danial; Earls refused to open the cell after being informed of the situation and medical requests.
- Jennings, though aware of Danial’s prior head-banging, did not call a Code 16 and instead sought supervisor guidance, delaying action.
- District court denied summary judgment to Farnsworth, Earls, and Jennings on deliberate indifference; court held Farnsworth and Earls could be liable, Jennings at most negligent; final disposition: denial affirmed for Farnsworth and Earls, reversed for Jennings on deliberate indifference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Farnsworth’s knowledge supports deliberate indifference | Lettermans: Farnsworth knew of risk based on medical requests and padded cell policy. | Farnsworth: no direct knowledge of Danial’s distress; acted reasonably. | Yes; knowledge inferred from circumstances, denial of immunity affirmed. |
| Whether Earls’s inaction constitutes deliberate indifference | Lettermans: Earls knew of risk from nurse and guard reports and refused to act. | Earls: Danial sleeping; no substantial risk shown. | Yes; knowledge and inaction support denial of immunity. |
| Whether Jennings’s conduct amounts to deliberate indifference | Lettermans: Jennings delayed action and relied on questionable nurse statements. | Jennings: attempted to escalate and sought supervision; not deliberately indifferent. | No; at most negligence; district court to grant Jennings judgment on the claim. |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (establishes subjective element of deliberate indifference)
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (premise that deliberate indifference violates Eighth Amendment)
- Jackson v. Everett, 140 F.3d 1149 (8th Cir. 1998) (knowledge may be inferred from obvious risk)
- Gordon v. Frank, 454 F.3d 858 (8th Cir. 2006) (deliberate indifference requires knowledge and disregard)
- Krout v. Goemmer, 583 F.3d 557 (8th Cir. 2009) (recklessness standard; inference from obvious risk supports knowledge)