Regina Barton v. Chad Ledbetter
908 F.3d 1119
8th Cir.2018Background
- On Sept. 12, 2011 Jeffry Barton was arrested after a single-vehicle accident and tests showing alcohol and hydrocodone; he was confused, slurred, unable to stand without help, and briefly unresponsive during booking.
- Deputy Amie Martin completed an intake report noting heavy intoxication, inability to answer basic questions, and that Barton could not sign or identify next of kin, but she did not perform the detention center’s required healthcare screening and admitted him to a holding cell without medical clearance.
- Barton was observed deteriorating overnight and was found dead in his cell at 12:03 a.m.; autopsy showed a congenital heart condition and small amounts of ethanol and hydrocodone.
- Jail administrator George Wright had no direct contact with Barton; he was responsible for training and supervising detention staff and conceded he did not fully understand all County policies regarding medical screening and intake.
- District court denied qualified immunity for Martin and Wright and found a triable issue whether the County maintained an unconstitutional custom; this appeal challenges the denials of qualified immunity and the County’s appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Martin’s failure to obtain medical care violated due process (deliberate indifference) | Martin’s obvious intoxication, recent accident, inability to follow questions/sign, and failure to screen show objective serious medical need and Martin’s deliberate indifference | Barton was merely intoxicated; no objectively serious medical need and Martin lacked subjective knowledge | Denied qualified immunity for Martin; jury could find objective serious need and that Martin knew and disregarded it |
| Whether Wright is liable for failure to train/supervise (supervisory liability) | Wright failed to ensure proper training/supervision causing deprivation | No evidence Wright had notice that training/supervision were inadequate; plaintiff offered no specifics of prior similar incidents | Reversed denial of qualified immunity for Wright; plaintiff failed to show Wright had requisite notice |
| Whether state-law (Arkansas Civil Rights Act) claims mirror federal standard | State claim uses same deliberate-indifference standard for pretrial detainees | Same as plaintiff | Wright entitled to summary judgment; Martin not entitled to summary judgment |
| Appellate jurisdiction over County’s appeal | County contends denial of summary judgment on municipal liability is reviewable here | Collateral-order jurisdiction limited to abstract legal questions; pendent jurisdiction not available | County’s appeal dismissed for lack of jurisdiction |
Key Cases Cited
- Mitchell v. Forsyth, 472 U.S. 511 (establishes collateral-order doctrine for qualified immunity appeals)
- Barton v. Taber, 820 F.3d 958 (8th Cir. 2016) (prior decision denying qualified immunity to arresting trooper; standards for intoxicated arrestees)
- Thompson v. King, 730 F.3d 742 (8th Cir. 2013) (denial of qualified immunity where detainee passed out, could not sign or answer questions)
- Grayson v. Ross, 454 F.3d 802 (8th Cir. 2006) (contrast case where detainee’s calm behavior did not present obvious medical need)
- Tlamka v. Serrell, 244 F.3d 628 (8th Cir. 2001) (standards for supervisory liability: notice and deliberate indifference)
- Lockridge v. Bd. of Trs. of Univ. of Ark., 315 F.3d 1005 (8th Cir. 2003) (limits appellate jurisdiction over pendent municipal claims)