Sours v. Big Sandy Regional Jail Authority, 593 F. App'x 478

James Sours, a pretrial detainee with Type I diabetes, was admitted to Big Sandy Regional Jail on July 13, 2010 with a blood sugar of 274 mg/dl and died July 15 from diabetic ketoacidosis after his insulin was not administered.
Nurse Allison was the sole medical staff at intake and remained in contact with Sours but did not administer insulin or obtain his regular insulin despite elevated blood sugar and ketoacidosis risk.
Sours reported not having insulin and Allison recorded inconsistent notes about whether he had taken insulin; she relied on a sliding scale that she failed to implement with insulin order and access.
Despite rising glucose levels (254–327 mg/dl) and obvious ketoacidosis symptoms, Allison did not arrange insulin administration, transfer to acute care, or hospital evaluation, and left the jail for a five-day weekend with no on-site medical staff.
Guards and supervisors on subsequent shifts observed Sours’ worsening condition (nausea, chest pains, weakness) but did not provide timely medical intervention or escalate to medical staff, contributing to the delay before emergency care.
Sours was found unresponsive around 10:40 pm on July 15 and died shortly after, with a blood glucose of 1629 mg/dl; the court granted summary judgment for the remaining defendants but reversed for Nurse Allison and remanded for trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Allison violate the Fourteenth Amendment by showing deliberate indifference to Sours’ serious medical needs?	Allison knew Sours was diabetic with rising glucose and refused to act.	District court found no deliberate indifference; actions were not unreasonable given information.	Yes; a jury could find deliberate indifference by conscious unreasonable inaction.
Does Kentucky official-immunity shield Nurse Allison from state-law negligence claims?	Medical care is ministerial and not protected by immunity when standard of care is violated.	Allison acted in good faith; actions were discretionary within immunity.	No; actions violated standard of care and there was bad faith; immunity not applicable.
Are the remaining defendants entitled to summary judgment on § 1983 and state-law claims?	Monell and supervisory liability should be considered given systemic failures.	No evidence of policy or custom causing deliberate indifference by others.	Affirmed; summary judgment for remaining defendants affirmed.

Garretson v. City of Madison Heights, 407 F.3d 789 (6th Cir. 2005) (inference of substantial risk from detainee’s condition supports knowledge element)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference defined as knowing risk and disregarding it)
Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (pretrial detainees have constitutional right to adequate medical care)
Phillips v. Roane County, 534 F.3d 532 (6th Cir. 2008) (diabetic inmate’s symptoms can show substantial risk and knowledge by guards)
Watkins v. City of Battle Creek, 273 F.3d 682 (6th Cir. 2001) (tests for Fourteenth Amendment medical-deliberate indifference apply same as Eighth)