Stafford v. McCurtain County Jail Trust, 6:10-cv-00030

Stafford was booked into MCDC on October 31, 2008 for two counts of Unlawful Delivery of a Narcotic and reported a history of high blood pressure requiring lisinopril.
An initial medical screening occurred November 3, 2008; nurse Wendt did not personally examine but authorized filling lisinopril after reviewing paperwork and a prior prescription.
Prescription for lisinopril, 5 mg daily, was secured and Staff ord began taking the medication on November 4, 2008; she later alleges receiving half-pills on two occasions due to a shortage.
Stafford contends she repeatedly asked to see a nurse for dizziness and headaches, but she allegedly did not see medical staff before December 7, 2008.
On December 7, 2008, Stafford experienced severe distress; Stewart observed symptoms she believed were a seizure, summoned EMS, and Stafford was later treated at OU Medical Center where she underwent craniotomy for a brain aneurysm.
The MCDC had written policies permitting daily medical complaints and a separate medications procedure, but Stafford disputes adherence to these policies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Stewart's conduct violated Stafford's constitutional rights	Stafford contends Stewart delayed/denied medical care for high blood pressure.	Defendants argue no deliberate indifference; no verified requests were made to Stewart.	Factual dispute precludes summary judgment on Stewart; claim survives as to Stewart.
Whether Lincoln's actions or supervision supports §1983 liability	Stafford asserts supervisor liability for medical care handling.	Lincoln had no personal participation or supervisory connection to the alleged denial/delay.	No basis for individual liability against Lincoln.
Whether the McCurtain County Jail Trust can be liable under Monell	Trust policy changes (no separate sick call log) show a training/policy failure causing violation.	No constitutional violation tied to Trust policy; Lincoln's actions do not establish a policy or custom.	No Monell liability; policy change not linked to a constitutional violation.
Whether Stafford's state-law negligence claim is barred by OGTCA	Trust negligently disregarded medical treatment.	OGTCA immunizes the Trust for prison-operations-related medical care.	OGTCA immunity applies; state-law negligence claim barred.

Estelle v. Gamble, 429 U.S. 97 (U.S. Supreme Court, 1976) (deliberate indifference to serious medical needs violates the Eighth Amendment)
Farmer v. Brennan, 511 U.S. 825 (U.S. Supreme Court, 1994) (objective and subjective components of deliberate indifference)
Saucier v. Katz, 533 U.S. 194 (U.S. Supreme Court, 2001) (two-step qualified immunity analysis; whether right was clearly established)
Harlow v. Fitzgerald, 457 U.S. 800 (U.S. Supreme Court, 1982) (immunity from suit for officials performing discretionary functions)
Monell v. Dept. of Social Services, 436 U.S. 658 (U.S. Supreme Court, 1978) (local governments liable under §1983 only for official policy or custom)
Board of County Commissioners v. Brown, 520 U.S. 397 (U.S. Supreme Court, 1997) (municipal liability requires moving force behind the injury)
Sealock v. Colorado, 218 F.3d 1205 (10th Cir. 2000) (timing and awareness of medical needs; evidence to support deliberate indifference)
Fogarty v. Gallegos, 523 F.3d 1147 (10th Cir. 2008) (supervisor/municipal liability standards in §1983 actions)