Randall Corwin v. City of Independence, MO.
2016 U.S. App. LEXIS 13087
| 8th Cir. | 2016Background
- Randall Corwin was arrested after injuring his hand on Oct. 30, 2012, and held first by Independence, MO, then transferred to Ray County Correctional Facility under a contract with the City of Independence.
- Corwin complained about his hand during transport and at booking; on Nov. 1 nurse Aleisa Moeller examined him, gave ibuprofen, applied an ACE wrap, and placed his request form in a folder that put him on the list to see the contract jail doctor.
- Corwin alleged the City directed Moeller not to take him to the emergency room and that no timely transport or appointment occurred; he was released on Nov. 6 before seeing the contract doctor.
- After release Corwin received treatment, had surgery and therapy, and claims lasting impairment, but the summary judgment record contains no medical evidence linking the five-day delay to worsening of his injury.
- Corwin sued Moeller and jail administrator Margaret Farnan under 42 U.S.C. § 1983 for deliberate indifference; he also sued the City of Independence and Ray County alleging municipal policy/custom. The district court granted summary judgment for the individuals and judgment on the pleadings for the municipal defendants; the Eighth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Moeller exhibited deliberate indifference in treating Corwin's fractured hand | Moeller provided inadequate care and failed to obtain more timely doctor/ER treatment, causing harm | Moeller examined him, provided medication and bandage, and placed him on the doctor list; delay at most negligence | Court: No deliberate indifference; summary judgment for Moeller (insufficient evidence that delay caused harm and mere disagreement/negligence insufficient) |
| Whether Moeller’s placement of Corwin on the doctor list (rather than immediate ER) constituted an unconstitutional delay | Failure to take affirmative steps (transport/ER) amounted to deliberate indifference | Nurse followed procedures and placed him on list; no proof delay worsened condition | Court: No; plaintiff offered no verifying medical evidence that delay had detrimental effect, so claim fails |
| Whether Farnan (jail administrator) was deliberately indifferent by failing to schedule transport | Farnan should be liable because scheduling transport was her responsibility and thus she knew or should have known | Record lacks evidence Farnan was actually aware of Corwin's condition; at most a duty to supervise | Court: No deliberate indifference; summary judgment for Farnan (no proof of actual knowledge or causation) |
| Whether City of Independence and Ray County are liable for unofficial custom/policy or failure to train/supervise | Municipal agreement/practice allegedly produced a custom of not taking injured Independence detainees to ER | Municipal defendants argued no official policy alleged and isolated incident cannot establish municipal custom; also individual liability not shown | Court: Judgment on pleadings for municipalities; plaintiff failed to plead a widespread/custom pattern and cannot establish municipal liability absent individual liability |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (deliberate indifference standard for prisoner medical care)
- Popoalii v. Correctional Medical Services, 512 F.3d 488 (deliberate indifference requires more than negligence)
- Laughlin v. Schriro, 430 F.3d 927 (need verifying medical evidence to show detrimental effect from delay)
- Monell v. Department of Social Services, 436 U.S. 658 (municipal liability standards under § 1983)
- City of Canton v. Harris, 489 U.S. 378 (failure to train can create municipal liability if deliberately indifferent)
- Farmer v. Brennan, 511 U.S. 825 (subjective awareness requirement for deliberate indifference)