Knouse v. Primecare Medical of West Virginia, Inc.
2:18-cv-01014
S.D.W. VaSep 24, 2018Background
- Decedent Dr. Charles Knouse, a federal pretrial detainee, alleged serious cardiac and other medical needs and told jail staff he required ongoing medications; Magistrate Judge Aboulhosn ordered immediate placement in the medical unit and resumption of prescribed medications.
- Despite the court order, Knouse was moved to mainline housing, later put on suicide watch, and repeatedly reported chest pain and very low heart rates to jail staff overnight.
- Staff allegedly failed to provide emergency medical care or notify treating physicians; Knouse was found unresponsive and pronounced dead the next morning.
- Plaintiff Hannah Knouse (administrator) sued WVRJA, jail officials (Douglas and Chandler), PrimeCare employees, and others, asserting § 1983, ADA, multiple state tort and constitutional claims, and related counts.
- WVRJA, Douglas, and Chandler moved to dismiss under Rule 12(b)(6), raising immunity and pleading-failure defenses; the court considered § 1983, qualified immunity, ADA, and state-law pleading adequacy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of § 1983 to WVRJA and officials in official capacity | § 1983 claims brought against state agency and officials | WVRJA and officials (in official capacity) are state actors not "persons" under § 1983 | Dismissed with prejudice (Will controls) |
| Individual-capacity § 1983 deliberate-indifference (Fourteenth Amendment) | Douglas and Chandler failed to follow court order, ignored known serious medical needs, causing death | Officials claim qualified immunity and insufficiently pleaded constitutional violation | Claim survives against Douglas and Chandler in individual capacities; motions denied on this issue |
| Qualified immunity: was right "clearly established"? | Plaintiff: right to adequate medical care and freedom from deliberate indifference is clearly established | Defendants: argue either no constitutional violation or lack of clearly established law | Court: right was clearly established; factual allegations sufficient to defeat dismissal on qualified immunity at this stage |
| ADA Title II claim | Decedent was a disabled individual denied benefits because of disability | Defendants: complaint fails to plead that decedent was a "qualified individual" or that denial was because of disability | ADA claim dismissed for failure to plead disability status and causation |
| State-law tort and state-constitutional claims against Prison Defendants | Various negligence, medical malpractice, state-constitutional claims | Defendants: pleading is shotgun-style, conclusory, and fails to show which facts apply to which defendants or that statutory elements are met | State-law claims against Prison Defendants dismissed without prejudice for failure to state claims (shotgun pleading) |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standards; courts need not accept legal conclusions)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Will v. Michigan Dep't of State Police, 491 U.S. 58 (1989) (states and officials sued in official capacity are not "persons" under § 1983)
- Hafer v. Melo, 502 U.S. 21 (1991) (state officials sued in individual capacities are "persons" under § 1983)
- Reichle v. Howards, 566 U.S. 658 (2012) (qualified immunity two-step framework)
- Ashcroft v. al-Kidd, 563 U.S. 731 (2011) ("clearly established" standard for qualified immunity)
- Malley v. Briggs, 475 U.S. 335 (1986) (qualified immunity protects all but plainly incompetent or those who knowingly violate the law)
- Scinto v. Stansberry, 841 F.3d 219 (4th Cir. 2016) (defining right to adequate medical care for qualified-immunity purposes)
- Hope v. Pelzer, 536 U.S. 730 (2002) (clearly established rights may be found without identical prior facts)
- Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to serious medical needs violates Eighth Amendment)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard; risk must be known or obvious)
- Parrish ex rel. Lee v. Cleveland, 372 F.3d 294 (4th Cir. 2004) (facts showing longstanding, pervasive, or well-documented risk)
- Miltier v. Beorn, 896 F.2d 848 (4th Cir. 1990) (failure to respond to known medical needs raises inference of deliberate indifference)
- Cooper v. Dyke, 814 F.2d 941 (4th Cir. 1987) (pretrial detainees have heightened Fourteenth Amendment protection)
- Martin v. Gentile, 849 F.2d 863 (4th Cir. 1988) (deliberate indifference standard applies to pretrial detainees)
- Whisenant v. Yuam, 739 F.2d 160 (4th Cir. 1984) (deliberate indifference standard for pretrial detainee claims)
- Loe v. Armistead, 582 F.2d 1291 (4th Cir. 1978) (prisoners' right to adequate medical care recognized)