Rife v. Oklahoma Department of Public Safety
2017 U.S. App. LEXIS 1117
10th Cir.2017Background
- Clyde Rife was found dazed on a motorcycle roadside with dried blood, grass stains, slurred speech, memory loss (could not state day/time/social security), and signs consistent with either intoxication or head/trauma injury.
- Trooper Jefferson administered field sobriety and HGN tests (Rife showed all HGN clues and failed/was unable to complete other tests) and arrested Rife for public intoxication, believing he had taken excessive pain medication.
- While en route to and at the jail, Rife groaned and complained of chest/heart and stomach pain; he was placed in a holding cell and received no medical evaluation.
- Rife sued: (1) under 42 U.S.C. § 1983 for wrongful arrest (Trooper) and for deliberate indifference to serious medical needs (Trooper, two jail officials, and jail trust municipal claim), and (2) under the Oklahoma Governmental Tort Claims Act for vicarious liability/negligence (Oklahoma Department of Public Safety).
- District court granted summary judgment for all defendants (probable cause for arrest; no deliberate indifference or negligence; denied spoliation sanctions). The Tenth Circuit: affirmed probable-cause/wrongful-arrest holdings; reversed as to deliberate indifference and negligence claims and remanded; affirmed denial of spoliation sanctions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for warrantless arrest (Trooper Jefferson) | Rife: Trooper lacked probable cause because symptoms could indicate head injury, Trooper cited wrong statute, and Rife denied taking medication | Trooper: observations and HGN/sobriety tests provided probable cause; even a mistaken statutory citation is immaterial | Held: Probable cause existed; arrest justified (affirmed) |
| Vicarious liability of Oklahoma DPS for wrongful arrest | Rife: DPS liable under state tort claims act for trooper’s wrongful arrest | DPS: Probable cause defeats wrongful-arrest tort liability | Held: Affirmed — no tort liability because arrest was supported by probable cause |
| Deliberate indifference to serious medical needs (Trooper; jail officials Willis & Dale; jail trust municipal liability) | Rife: complaints of chest/stomach pain, groaning, visible blood, disorientation, and accident history made medical need obvious; failure to obtain care shows conscious disregard; jail trust policies/customs caused violation | Defendants: symptoms consistent with intoxication, no obvious trauma/head injury, no request for care, qualified immunity | Held: Reversed for these claims — reasonable factfinder could find deliberate indifference as to Trooper, Willis, Dale; municipal claim survives to permit factfinding on causation/policy and clearly-established-right issues (remanded) |
| Negligence (Oklahoma DPS vicarious liability for Trooper’s failure to obtain medical attention) | Rife: Trooper’s failure to secure medical attention was unreasonable given his condition and complaints | DPS: Trooper acted reasonably (no visible injuries, symptoms consistent with intoxication, ruled out head injury) | Held: Reversed — genuine dispute of material fact exists on reasonableness; remanded |
Key Cases Cited
- Devenpeck v. Alford, 543 U.S. 146 (officer’s subjective arrest reason need not match statute that actually provides probable cause)
- Farmer v. Brennan, 511 U.S. 825 (subjective knowledge and conscious disregard standard for deliberate indifference)
- Cortez v. McCauley, 478 F.3d 1108 (10th Cir.) (probable-cause standard for warrantless arrest)
- Sealock v. Colorado, 218 F.3d 1205 (10th Cir.) (deliberate indifference standard applied to detainees)
- Hirsch v. Burke, 40 F.3d 900 (7th Cir.) (probable cause where medical condition mimicked intoxication)
- Qian v. Kautz, 168 F.3d 949 (7th Cir.) (officer’s observations after crash supported probable cause)
- Martinez v. Beggs, 563 F.3d 1082 (10th Cir.) (deliberate indifference analysis for pretrial detainees)