Jones v. Muskegon County
2010 U.S. App. LEXIS 23034
| 6th Cir. | 2010Background
- Jones, in Muskegon County Jail custody as a pretrial detainee, rapidly lost weight and developed severe abdominal symptoms from late 2004 to May 2005.
- Plaintiff claims medical kites were ignored by jail staff, with affidavits alleging guards and nurses failed to provide timely care while Jones deteriorated.
- Medical evaluation began March 26, 2005; Dr. Deitrick examined March 29, 2005 and treated Jones for obstipation, followed by imaging and tests.
- Jones was transferred to Hackley Hospital on April 8, 2005 after his condition worsened; a large cancerous mass was found via exploratory surgery on April 9, 2005.
- Jones died May 5, 2005; Plaintiff asserted §1983, gross negligence, and intentional infliction of emotional distress claims against the Corrections Officers, nurses, the County, and the jail doctor.
- The district court granted summary judgment on all claims; the Sixth Circuit affirmed some, reversed others, and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did defendants violate §1983 via deliberate indifference? | Jones's evidence shows denial of medical care and knowledge of risk. | Care was provided; no officer or nurse acted with deliberate indifference. | Partial §1983 liability reversed for Nurses Mastee and Yonker; others affirmed or excluded. |
| Are Nurses Mastee and Yonker liable for §1983 and gross negligence? | These nurses ignored kites indicating serious illness. | No evidence of culpable mind or gross negligence for these individuals. | §1983 and gross negligence claims against Mastee and Yonker survive; Malenko barred at this stage. |
| Is Dr. Deitrick subject to §1983 liability for deliberate indifference? | Initial misdiagnosis and delayed escalation amounted to deliberate indifference. | Initial diagnosis may be negligent but not deliberately indifferent; actions escalated appropriately. | Dr. Deitrick's actions not grossly negligent; no §1983 liability established. |
| Can the County be held liable under Monell for a custom or policy of indifference? | Customs evidenced by multiple inmate affidavits show a policy of ignoring medical needs. | Isolated incidents and a single employee statement do not show a widespread custom. | County summary judgment affirmed; no evidence of an actionable custom. |
| Does Michigan law support intentional infliction of emotional distress against the defendants? | Extreme conduct occurred through sustained disregard for medical needs. | Conduct was not extreme or outrageous enough to satisfy the standard. | Summary judgment affirmed for all defendants on this claim. |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference standard in medical care claims)
- Farmer v. Brennan, 511 U.S. 825 (1994) (objective vs. subjective components of medical need; deliberate indifference defined)
- Blackmore v. Kalamazoo County, 390 F.3d 890 (6th Cir. 2004) (deliberate indifference can be shown by refusal to treat a serious need)
- Monell v. New York City Dept. of Social Servs., 436 U.S. 658 (1978) (municipal liability for official policy or custom)