Sims v. Griffin
35 F.4th 945
| 5th Cir. | 2022Background
- Steven Qualls, a known drug user, was taken from a hospital to Jasper City Jail after police arrested him for public intoxication; he likely swallowed a bag of narcotics before arrest.
- Over ~34 hours in a jail detox cell, Qualls repeatedly vomited dark/black liquid, moaned, convulsed, hallucinated, cried for help, and asked to go to a hospital; officers observed deterioration but did not summon EMS.
- Jail officers Griffin and Linebaugh and dispatcher O’Dell cleaned Qualls and his cell at times, saw drug paraphernalia and vomit, and heard his repeated pleas; Qualls was later found dead with rigor mortis set.
- Qualls’s mother Sims sued under 42 U.S.C. § 1983 alleging the officers were deliberately indifferent to his serious medical needs; the district court denied the officers’ summary-judgment/qualified-immunity motion.
- On interlocutory appeal, the Fifth Circuit reviewed whether the district-court-identified fact disputes were material and whether the law was clearly established, and affirmed the denial of qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers violated Qualls’s constitutional right by deliberate indifference to serious medical needs | Sims: officers knew facts (swallowed bag, repeated vomiting, cries for help, deterioration) that a layperson would recognize as requiring medical care and they ignored him | Officers: they monitored, cleaned, and responded; they did not know extent/need for medical care; disputed facts preclude finding of constitutional violation | Material fact disputes identified by district court are material; court may not resolve genuineness now and a reasonable jury could find deliberate indifference |
| Whether this interlocutory appeal is jurisdictionally barred (genuineness vs materiality) | Sims: appeal challenges genuineness only and thus is beyond interlocutory jurisdiction | Officers: appeal raises materiality and other reviewable legal questions | Court denied Sims’s motion to dismiss; panel had jurisdiction to review materiality and certain legal issues |
| Whether Qualls’s right was clearly established at the time (qualified-immunity prong 2) | Sims: Easter and related precedent put officers on notice that ignoring serious medical complaints and refusing care violates the Constitution | Officers: prior law is too general; their actions not analogous | Court: law was clearly established (Easter and related precedents) so qualified immunity not warranted at this stage |
| Proper legal standard (subjective intent for pretrial detainees) | Sims preserved argument to replace subjective test with objective standard | Officers: assert subjective deliberate-indifference standard applies | Issue foreclosed by precedent; Fifth Circuit applied subjective standard consistent with circuit precedent |
Key Cases Cited
- Easter v. Powell, 467 F.3d 459 (5th Cir. 2006) (officials’ refusal/ignoring of prisoner’s severe medical complaints shows wanton disregard)
- Domino v. Texas Dep’t of Crim. Just., 239 F.3d 752 (5th Cir. 2001) (framework for deliberate-indifference analysis)
- Gobert v. Caldwell, 463 F.3d 339 (5th Cir. 2006) (definition of "serious medical need")
- Farmer v. Brennan, 511 U.S. 825 (Sup. Ct. 1994) (subjective deliberate-indifference standard in constitutional claims)
- Mullenix v. Luna, 577 U.S. 7 (Sup. Ct. 2015) (standard for when law is "clearly established" for qualified immunity)
- District of Columbia v. Wesby, 138 S. Ct. 577 (Sup. Ct. 2018) (rights must be defined with particularity to overcome qualified immunity)
- Roque v. Harvel, 993 F.3d 325 (5th Cir. 2021) (de novo review of qualified-immunity denials and burden-shifting principles)