Kirk Williams v. Claudia Balducci, Et Ano.
73766-0
| Wash. Ct. App. | Jun 19, 2017Background
- Williams, a pretrial detainee at King County Jail (June 2010–Sept 2011), sued under 42 U.S.C. § 1983 claiming jail staff were deliberately indifferent to his medical needs after he later tested positive for tuberculosis (TB).
- Defendants: Dr. Benjamin Sanders (Medical Director, Jail Health Services) and Claudia Balducci (Director, Dept. of Adult & Juvenile Detention). Williams alleged they failed to screen/treat TB and that he contracted TB from other inmates.
- Williams produced inmate declarations asserting exposure or lack of TB testing by other inmates; none identified direct contact with or decisions by Sanders or Balducci.
- Dr. Sanders submitted records showing no TB risk factors for Williams, that TB testing was provided by protocol (foreign-born receive test; all offered test within 14 days or on request), and that staff would isolate symptomatic inmates.
- Balducci declared she had no medical or housing decision role concerning Williams and had no contact with him.
- Trial court initially denied summary judgment but, on reconsideration, granted summary judgment for defendants; appellate court affirmed, finding no evidence defendants knew of and disregarded a serious risk or made intentional confinement decisions causing harm.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendants were deliberately indifferent to Williams' serious medical needs under Fourteenth/Eighth Amendment standards | Williams: jail failed to properly screen/treat for TB; defendants’ policies/practices caused his infection | Sanders: medical records show no risk factors or symptoms; testing offered by protocol; Balducci: no role/contacts with Williams | Court: No triable issue—no evidence defendants knew of and disregarded a serious risk or made intentional confinement decisions |
| Whether objective Castro/Kingsley standard or subjective Farmer standard governs pretrial detainee claim | Williams: alleges systemic failure to protect from TB exposure (argues for liability) | Defendants: even under either standard, no evidence of intentional decision or subjective knowledge/disregard | Court: Applied both standards; Williams fails under either—no intentional act or subjective awareness shown |
| Admissibility/weight of inmate declarations as evidence of defendants' liability | Williams: declarations show others lacked testing and possible exposure; infer defendants' indifference | Defendants: declarations are speculative, lack personal knowledge of defendants' actions or symptoms, and are temporally/causally disconnected | Court: Declarations insufficient—speculative, lacked linkage to defendants or proof of symptoms/risk at relevant times |
| Whether appellate court may consider materials not presented to trial court | Williams: appended extra materials to appellate brief | Defendants: review limited to trial record | Court: Declined to consider new materials per RAP 9.12 and 10.3(8) |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate indifference to serious medical needs requires more than inadvertent failure to provide care)
- Bell v. Wolfish, 441 U.S. 520 (1979) (Fourteenth Amendment standards govern pretrial detainee conditions-of-confinement claims)
- Farmer v. Brennan, 511 U.S. 825 (1994) (subjective deliberate indifference standard: official must know and disregard excessive risk)
- Kingsley v. Hendrickson, 576 U.S. 389 (2015) (adopted objective standard for certain pretrial detainee claims)
- Castro v. County of Los Angeles, 833 F.3d 1060 (9th Cir. 2016) (articulated four-part objective test for pretrial detainee failure-to-protect claims)