Ruth Denham v. Corizon Health, Inc.
675 F. App'x 935
| 11th Cir. | 2017Background
- Tracy Lee Veira, a pretrial detainee, was booked into Volusia County Jail; Corizon Health provided jail medical services. Prescription opioids and benzodiazepines were discontinued at booking.
- Three days after booking medical staff diagnosed Veira with opiate withdrawal, put her on a treatment protocol, and placed her in medical segregation on a 15‑minute watch (to be performed by corrections officers, not clinicians).
- Veira exhibited worsening symptoms over several days; nurses and a nurse practitioner interacted with her, but officers’ watch entries often reported routine observations. She was found dead in her cell on day six with signs consistent with severe vomiting, aspiration, dehydration, and opiate withdrawal.
- Evidence showed some prior instances of missed/falsified watches and at least one other inmate found dead; supervisors sometimes assisted with falsified watch sheets and officers had been disciplined in some prior instances.
- Denham, personal representative, sued Volusia County and Corizon under 42 U.S.C. § 1983 alleging Fourteenth Amendment deliberate indifference via policies/customs (failure to train, falsified watches, inadequate intake, inadequate medical care, understaffing).
- The district court granted summary judgment for defendants; the Eleventh Circuit affirmed, holding Denham failed to show a municipal or private‑entity custom/policy of deliberate indifference that caused Veira’s death.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Veira suffered constitutional violation (deliberate indifference to serious medical need) | Veira had serious medical needs from opioid withdrawal and defendants were deliberately indifferent | Defendants contended they provided medical care and monitoring per protocols and officers received emergency training; any failures were isolated | Court assumed violation could be shown but required municipal/custom link; plaintiff failed other elements for municipal liability |
| Failure‑to‑train liability against Volusia County and Corizon | County and Corizon failed to train officers who performed 15‑minute watches and other duties, showing deliberate indifference | Training was provided for emergency duties; non‑medical duties were not assigned to officers; plaintiff offered only isolated incidents, not an obvious need for more training | No pattern or obvious need shown; summary judgment for defendants on failure‑to‑train theory |
| Municipal/custom liability for falsified watch records | County had a custom of falsifying watch sheets to cover missed watches, which caused Veira’s death | County argued falsification was disciplinary misconduct unknown to policymakers and not officially sanctioned; supervisors disciplined officers when identified | No evidence that policymakers knew and acquiesced; practice not properly attributable to County, so no municipal liability |
| Corporate liability (Corizon) for widespread inadequate care or intake failures | Corizon had customs of improper intakes and inadequate care that caused delayed diagnosis/treatment leading to death | Corizon argued interactions with Veira occurred and plaintiff showed at most isolated incidents insufficient to establish a widespread custom or causal link to death | Plaintiff failed to show a pattern of similar incidents or a direct causal link; summary judgment affirmed |
Key Cases Cited
- Monell v. Dep’t of Soc. Servs. of N.Y., 436 U.S. 658 (municipal liability requires an official policy or pervasive custom)
- Canton v. Harris, 489 U.S. 378 (failure‑to‑train municipal liability requires deliberate indifference and obvious need)
- Bd. of Cty. Comm’rs v. Brown, 520 U.S. 397 (liability for unofficial customs when practice is widespread enough to have force of law)
- Connick v. Thompson, 563 U.S. 51 (pattern of violations required to show obvious need for training)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden shifting principles)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (nonmovant must present more than metaphysical doubt to defeat summary judgment)
- Oklahoma City v. Tuttle, 471 U.S. 808 (single incident generally insufficient to establish municipal custom)
- Craig v. Floyd Cty., 643 F.3d 1306 (Eleventh Circuit standards for § 1983 municipal and private‑entity liability)
- McDowell v. Brown, 392 F.3d 1283 (Eleventh Circuit articulation of elements for municipal § 1983 claim)