Richardson v. Falk, 2:23-cv-10488

Plaintiff Larry Richardson, incarcerated at St. Louis Correctional Facility, experienced escalating chest pain on January 27, 2023 after a religious service.
Around 8:43 p.m. Richardson told corrections officer Nathan Falk he had “bad chest pains” and asked to be sent to healthcare; Falk told him to return to his cell.
Richardson was not transported to healthcare until about 8:52 p.m.; he suffered an active heart attack and collapsed while in medical care.
Richardson sued under 42 U.S.C. § 1983 alleging Eighth Amendment deliberate indifference and a Fourteenth Amendment due-process claim; he sought damages and injunctive relief.
Magistrate Judge Morris recommended denying Falk qualified immunity on the Eighth Amendment claim (so that claim proceed to trial) and dismissing the Fourteenth Amendment claim and injunctive relief.
The district court conducted a de novo review, adopted the R&R, overruled Falk’s objections, denied qualified immunity on the Eighth Amendment claim, and dismissed the Fourteenth Amendment claim and injunctive relief with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Richardson had an objectively serious medical need	Chest pain is an obvious, classic sign of a heart attack requiring immediate care	Symptoms were not sufficiently obvious; verifying medical evidence is needed	Triable issue: a reasonable jury could find chest pain objectively serious
Whether Falk acted with subjective deliberate indifference	Falk heard the complaint, ordered Richardson back to his cell, and thus consciously disregarded risk	Falk did not perceive a medical emergency and is not a medical professional	Triable issue: jury could find Falk knew of and disregarded a substantial risk
Whether Falk is entitled to qualified immunity	Existing precedent shows short delays in emergency care can violate the Eighth Amendment	No clearly established law that a <10-minute delay is unconstitutional	Denied: Tlamka and related precedent put a reasonable officer on notice; qualified immunity denied
Whether Fourteenth Amendment claim and injunctive relief survive	Plaintiff asserted due-process violation and sought discipline/termination	Defendant argued the claim is governed by the Eighth Amendment	Dismissed with prejudice: Fourteenth claim and injunctive relief denied

Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (Eighth Amendment prohibits deliberate indifference to serious medical needs)
Blackmore v. Kalamazoo Cnty., 390 F.3d 890 (6th Cir. 2004) (obvious medical needs can satisfy the objective component without expert proof)
Napier v. Madison Cnty., 238 F.3d 739 (6th Cir. 2001) (expert/medical evidence required where condition or delay effects are non-obvious)
Tlamka v. Serrell, 244 F.3d 628 (8th Cir. 2001) (delay of roughly ten minutes in emergency care can constitute deliberate indifference; qualified immunity denied)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference requires knowledge of and disregard of substantial risk)
Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (qualified immunity two-prong framework)