Sawyers v. Norton
962 F.3d 1270
| 10th Cir. | 2020Background
- In November 2015 Sawyers was arrested for arson and exhibited severe psychotic behavior (diagnosed schizophrenia, self‑harm, refusal of meds) while detained; SLVMH clinicians evaluated him multiple times and instructed close monitoring.
- Rio Grande County Jail placed Sawyers in an observation/booking cell and maintained a dedicated “Suicide Watch‑15 Min.” log; officers Hart, Hand, and Bruder were assigned to monitor him the evening of December 2, 2015.
- On December 2, officers left the booking area to prepare and distribute medication; the logs are incomplete for several hours and no surveillance video survives for the critical period; at about 9:15 p.m. officers found Sawyers had removed his right eye.
- Sawyers sued under 42 U.S.C. § 1983 (deliberate indifference to serious medical needs) against the three officers (individual capacity) and Sheriff Norton (individual and official capacity), and alleged state law negligence (individual and official capacity).
- The district court denied the officers’ qualified immunity motion (finding disputed facts for a jury and that the law was clearly established) and denied sovereign immunity to Rio Grande County on the official‑capacity negligence claim under the Colorado Governmental Immunity Act (CGIA); it granted other portions of defendants’ summary judgment motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers were deliberately indifferent (constitutional violation) | Sawyers: officers knew of risk (diagnoses, prior self‑harm, SLVMH warnings) and failed to properly monitor, enabling self‑mutilation | Officers: they monitored per policy, sought SLVMH advice, and were not subjectively aware of a substantial risk | Court: denial of qualified immunity on this factual question affirmed; appellate court lacks jurisdiction to reweigh district court factual inferences |
| Whether the constitutional right was "clearly established" | Sawyers: Tenth Circuit precedent places such duties on jail officials | Officers: the law was not clearly established as to their conduct | Court: officers waived this argument on appeal by inadequate briefing; denial of qualified immunity stands |
| Whether Rio Grande County is immune under CGIA for negligence arising from jail operation | Sawyers: CGIA waives immunity for injuries resulting from operation of a jail for pretrial detainees | County: argues immunity survives because employees would be personally immune for their acts | Court: waiver applies; county not entitled to sovereign immunity for the jail‑related negligence claim |
| Municipal liability (official‑capacity §1983) — policy/training failure alleged | Sawyers: county/sheriff maintained a deficient custom/policy and failed to train/ratified conduct | County: had policies using SLVMH, clinicians evaluated Sawyers, and no evidence of a deficient policy or training | Court: district court granted summary judgment for the county on municipal liability (no municipal §1983 liability) |
Key Cases Cited
- Fancher v. Barrientos, 723 F.3d 1191 (10th Cir. 2013) (limits appellate review of district court factual findings in qualified immunity appeals)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity two‑part test)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for prison officials)
- Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to serious medical needs actionable under § 1983)
- Burke v. Regalado, 935 F.3d 960 (10th Cir. 2019) (Fourteenth Amendment deliberate indifference analysis for pretrial detainees uses Eighth Amendment framework)
- Al‑Turki v. Robinson, 762 F.3d 1188 (10th Cir. 2014) (objective component: diagnosis or obvious need for medical care)
- Garcia v. Salt Lake Cty., 768 F.2d 303 (10th Cir. 1985) (deliberate indifference precedent relied on by district court)
- Martin v. Bd. of Cty. Comm'rs, 909 F.2d 402 (10th Cir. 1990) (deliberate indifference precedent relied on by district court)