Juana Villegas v. The Metro. Gov't of Nashville
2013 U.S. App. LEXIS 4382
| 6th Cir. | 2013Background
- Villegas, a pretrial detainee, was shackled during labor and postpartum while in custody of Metro Nashville/Davidson County; she also was denied a breast pump after hospital discharge.
- The English-language jail transport and hospital staffing actions resulted in leg irons and front handcuffs during ambulance transport and hospital stay; shackling phases extended into postpartum period.
- Hospital staff allegedly sought a no-restraint order, but officers did not receive explicit orders; one officer removed handcuffs temporarily but left a leg restraint.
- A detainer placed by ICE classified Villegas as a medium-security inmate, informing custody decisions and purported safety considerations.
- Plaintiff sued under 42 U.S.C. § 1983 alleging deliberate indifference to medical needs under the Eighth/ Fourteenth Amendment framework; summary judgment was granted against her on liability but reversed on appeal, remanding for trial on damages.
- The district court’s partial grant of summary judgment on shackling and breast-pump denial was reversed; the court held mixed facts create genuine disputes proper for jury resolution.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether shackling during labor/postpartum violated the Eighth Amendment. | Villegas contends shackling created a substantial risk and officers disregarded it. | Shackling was consistent with custody level and security concerns. | Summary judgment reversed; material disputes for trial on liability remain. |
| Whether denial of a breast pump postdischarge constitutes deliberate indifference. | Denial of pump worsened medical risk and pain post-delivery. | Pump was not prescribed; not a “critical medical device.” | Summary judgment reversed on liability; remand for trial on this claim. |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (establishes deliberate indifference standard for medical needs under Eighth Amendment)
- Farmer v. Brennan, 511 U.S. 825 (1994) (two-part objective/subjective test for deliberate indifference)
- Harrison v. Ash, 539 F.3d 510 (2008) (defines serious medical need and subjective knowledge aspects)
- Blackmore v. Kalamazoo Cnty., 390 F.3d 890 (2004) (defines serious medical need and medical-needs framework)
- Nelson v. Carr. Med. Servs., 583 F.3d 522 (2009) (recognizes crossover shackling claims and reliance on obvious risk)
- Spencer v. Bouchard, 449 F.3d 721 (2006) (discusses conditions-of-confinement framework applicability)
- Byrd v. Wilson, 701 F.2d 592 (1983) (early medical-needs/deliberate indifference guidance in care)
- Boretti v. Wiscomb, 930 F.2d 1150 (1991) (distinguishes when medical treatment plans are formally prescribed)