73 F.4th 1007
8th Cir.2023Background:
- Kelly Martin was found after a one-car accident with slurred, at-times incoherent speech; Deputy Jordan Turner suspected impairment and found pills in her purse, including medication sometimes used for seizures.
- Martin told Turner she was not hurt and denied medical problems; on-scene EMS observed her, and she refused further treatment and transport.
- Martin’s boyfriend said Martin had been driving to a hospital, had run out of pain medication, and “might have had a seizure.” Turner disputes being told about a seizure or her condition.
- Turner arrested Martin for DWI, took her (and her medications) to the county jail, where she was booked and detained overnight; Martin alleges she suffered multiple seizures in custody and was seriously injured.
- Martin sued Turner under 42 U.S.C. § 1983 and the Arkansas Civil Rights Act for deliberate indifference; the district court denied Turner qualified immunity on the individual-capacity claim. The Eighth Circuit reversed.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Turner was deliberately indifferent to Martin’s seizure-related medical needs | Turner knew (via boyfriend and meds) of seizure disorder/need for medication and disregarded the risk | Turner checked Martin, asked about injuries, EMS evaluated her (she refused transport), and he brought her meds to jail—no deliberate disregard | Court assumed plaintiff-favorable facts for review but did not resolve the merits; focused on qualified immunity inquiry |
| Whether Turner is entitled to qualified immunity (was the law clearly established?) | Prior Eighth Circuit deliberate-indifference cases give fair notice that Turner’s conduct violated rights | Prior cases are not sufficiently similar to place the constitutional violation beyond debate; Turner lacked fair notice | Reversed district court; Turner entitled to qualified immunity because existing precedent did not clearly establish the unlawfulness of his conduct |
Key Cases Cited
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity framework)
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard protecting officials except when law is clearly established)
- Ashcroft v. al-Kidd, 563 U.S. 731 (plaintiff must show precedent placed question beyond debate)
- Mullenix v. Luna, 577 U.S. 7 (clearly established inquiry must be context-specific)
- Kisela v. Hughes, 138 S. Ct. 1148 (fair notice focus for qualified immunity)
- Barton v. Taber, 820 F.3d 958 (8th Cir. 2016) (officer’s failure to seek care for severely impaired arrestee violated rights)
- Barton v. Taber, 908 F.3d 1119 (8th Cir. 2018) (standard of review for denial of qualified immunity)