Marchello McCaster v. Mary Clausen
684 F.3d 740
8th Cir.2012Background
- McCaster, an inmate with active tuberculosis, was admitted to RCCF for 56 days and transferred to a hospital two days before release as his condition worsened.
- Minnesota requires TB screening in prisons; TB is highly transmissible in confined, poorly ventilated jail environments.
- At intake, nurse Nancy Mattson documented weight and vital signs but did not elicit symptoms or repeatedly engage; Mantoux test administered and misread two days after injection.
- Over May–June, McCaster’s health deteriorated visibly; inmates and officers submitted numerous medical requests; nursing staff and supervisors failed to respond adequately.
- Mary Clausen examined McCaster on May 21 and May 28, noting worsening symptoms but providing limited evaluation and treatment; he received penicillin but could miss doses due to bed rest.
- McCaster was hospitalized in early June with extensive TB-related complications and remained hospitalized for about 3.5 months; he filed a §1983 suit alleging deliberate indifference; district court granted immunity to administrators and the county but denied immunity to five nurses; nurses appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mattson and Darling are entitled to qualified immunity | McCaster’s obvious illness meant knew of serious need and disregarded it. | Limited contact and brief interactions cannot show deliberate indifference; no actual knowledge of a serious need. | Mattson and Darling entitled to qualified immunity |
| Whether Clausen, Nelson, and Vodinelich were entitled to qualified immunity | Obvious medical needs were known to these nurses; repeated requests indicate deliberate indifference. | Requests were not responded to; but qualified immunity may attach if no clearly established knowing disregard. | Claussen, Nelson, and Vodinelich not entitled to qualified immunity |
Key Cases Cited
- Nelson v. Corr. Med. Servs., 583 F.3d 522 (8th Cir.2009) (deliberate indifference standard for inmate medical needs)
- Estelle v. Gamble, 429 U.S. 97 (U.S. Supreme Court 1976) (cruel and unusual punishment for failure to provide medical care)
- Harlow v. Fitzgerald, 457 U.S. 800 (U.S. Supreme Court 1982) (qualified immunity framework for government officials)
- Pearson v. Callahan, 555 U.S. 223 (U.S. Supreme Court 2009) (two-step inquiry for qualified immunity)
- Farmer v. Brennan, 511 U.S. 825 (U.S. Supreme Court 1994) (intent required for deliberate indifference under Eighth Amendment)
- Langford v. Norris, 614 F.3d 445 (8th Cir.2010) (purely legal issues in collateral-order review of qualified immunity)
- Krout v. Goemmer, 583 F.3d 557 (8th Cir.2009) (evidence required to show official knew of medical need)
- Mitchell v. Forsyth, 472 U.S. 511 (U.S. Supreme Court 1985) (scope of collateral-order review and legal standards for immunity)