Patricia Esch v. County of Kent. Mich., 699 F. App'x 509

Background

Stephen Stiles was arrested on a warrant and booked into the Kent County jail on May 31, 2011; he had epilepsy and a prescription for Dilantin (phenytoin) to be taken twice daily and had missed the prior night's dose.
At intake Nurse McFadden recorded Stiles’ seizure history and prescription, left a voicemail for the pharmacy, but did not ask when Stiles last took Dilantin or secure immediate medication.
Nurse West verified the prescription with the pharmacy later that morning and forwarded the chart for physician review rather than immediately obtaining or administering the drug.
Dr. Sova reviewed the chart during his shift, approved a prescription, and authorized administration at the jail’s scheduled medication round (8:00 p.m.); Nurse Booker was on later shift but there is no evidence she ever saw or acted on Stiles’ chart.
Stiles was found unresponsive in his cell at 8:13 p.m. and pronounced dead at 8:41 p.m.; cause of death was a fatal seizure.
Plaintiff (personal representative of Stiles’ estate) sued under 42 U.S.C. § 1983, alleging Monell claims against county actors and deliberate indifference by individual jail medical staff; the district court granted summary judgment for defendants and this appeal followed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Which constitutional standard governs inadequate-medical-care claims for a detainee (Fourth objective reasonableness vs. Fourteenth deliberate indifference)?	Fourth Amendment applies because Stiles had not had a probable-cause hearing and was akin to a free person.	Defendants argued Fourteenth applies and also contended Fourth was waived below.	Court assumed arguendo the Fourth Amendment (the more forgiving standard) but held the claims fail under either standard, so no need to decide the broader question.
Liability of Nurse McFadden for failing to obtain/administer Dilantin at intake	McFadden knew Stiles’ seizure history, prescription, and intoxication risk and failed to ask last-dose timing or secure immediate medication.	McFadden followed jail intake procedures: documented prescription, left pharmacy message, and turned chart over to day-shift nurse; no acute distress was apparent at intake.	Summary judgment affirmed for McFadden: a reasonable officer would not have deviated from verification/dispensation procedures based on the facts known at intake.
Liability of Nurse West for verifying prescription but not expediting medication	After verification, West should have sought a physician or otherwise expedited Dilantin administration.	West reasonably verified the prescription and forwarded the chart for physician review; no signs of an acute emergency required departing from routine procedure.	Summary judgment affirmed for West: steps taken were objectively reasonable.
Liability of Dr. Sova and Nurse Booker for delayed administration	Dr. Sova failed to ensure immediate dosing after prescribing; Booker should have administered once prescription entered.	No evidence Dr. Sova was told or saw any indication of exigency; Booker has no evidence she saw or acted on the chart.	Summary judgment affirmed: Dr. Sova’s and Booker’s conduct was not objectively unreasonable given the information available; no record evidence Booker was involved.
Monell liability for county/policy failures	County policies allowed 24-hour verification but plaintiff argues they were inadequate to protect detainees with urgent needs.	Policies required verification and allowed expedited care; procedures were followed and no emergency indicator existed in chart.	District court’s dismissal of Monell claims affirmed: policies were facially adequate and not shown to have caused the constitutional violation.

Key Cases Cited

Monell v. Dep't of Soc. Servs. of City of N.Y., 436 U.S. 658 (1978) (local government liability under § 1983 requires unconstitutional policy or custom)
Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to serious medical needs violates the Eighth Amendment)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires subjective awareness of substantial risk)
Aldini v. Johnson, 609 F.3d 858 (6th Cir. 2010) (discussing objective reasonableness under Fourth Amendment for arrestees/detainees)
Lanman v. Hinson, 529 F.3d 673 (6th Cir. 2008) (which constitutional standard applies depends on detainee status and process received)
Boone v. Spurgess, 385 F.3d 923 (6th Cir. 2004) (noting uncertainty whether Fourth Amendment governs inadequate-medical-care claims)
Williams v. Rodriguez, 509 F.3d 392 (7th Cir. 2007) (articulating four-factor test for objective unreasonableness in medical response)
Ortiz v. City of Chicago, 656 F.3d 523 (7th Cir. 2011) (applying the Williams four-factor framework and balancing totality of circumstances)
Florek v. Village of Mundelein, 649 F.3d 594 (7th Cir. 2011) (officers’ medical choices reasonable where an acute need was not apparent)
Tatum v. City & County of San Francisco, 441 F.3d 1090 (9th Cir. 2006) (discussing reasonableness standard for detainee medical claims)