Strain v. Regalado, 977 F.3d 984

Thomas Pratt was booked into the Tulsa County Jail in December 2015 and reported alcohol withdrawal; jail medical staff admitted him to the medical unit and documented withdrawal symptoms.
Over three days Pratt exhibited vomiting, severe tremors, disorientation, a head laceration, and episodes suggesting delirium tremens; staff placed him on seizure precautions and administered Librium then Valium.
Multiple assessments occurred (nurses, an LPC, and Dr. McElroy), but staff allegedly failed repeatedly to record vitals, escalate care, or send Pratt to a hospital.
Pratt suffered a cardiac arrest in jail and was later discharged from the hospital with a seizure disorder and permanent disability.
His guardian sued Armor Correctional Health Services, individual providers (Nurse Deane, LPC Loehr, Dr. McElroy), and the sheriff for deliberate indifference under 42 U.S.C. § 1983 and related state claims; the district court dismissed the federal claims and declined supplemental jurisdiction over state claims.
The Tenth Circuit affirmed: it held the deliberate indifference standard for pretrial detainees retains both objective and subjective components post-Kingsley and found the complaint failed to plead the subjective prong against any defendant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard for Fourteenth Amendment deliberate indifference after Kingsley	Kingsley requires only an objective unreasonableness test for pretrial detainees	Kingsley is limited to excessive-force/punishment context; deliberate indifference requires subjective intent	Court: Kingsley does not eliminate subjective prong; apply two-prong (objective + subjective) test
Sufficiency of allegations of deliberate indifference (general)	Pratt’s symptoms were obvious delirium tremens and staff ignored escalating risk	Providers performed assessments, gave medication, and observed him; at most negligence	Court: Allegations show attempts at treatment, not facts plausibly showing officials subjectively knew and disregarded a substantial risk; dismissal affirmed
Claims against individual providers (Deane, McElroy, Loehr)	Each failed to monitor, escalate, or transfer to hospital despite obvious risk	Providers made medical judgments and treated in-house; no conscious disregard alleged	Court: Dismissed claims—plaintiff failed to plead subjective awareness; Deane claim also waived for inadequate briefing
Supplemental jurisdiction over state-law claims	District court should retain state claims	District court may dismiss state claims after federal claims are dismissed	Court: Declining supplemental jurisdiction was within discretion; affirmed

Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (deliberate indifference to serious medical needs violates Eighth Amendment)
Kingsley v. Hendrickson, 576 U.S. 389 (U.S. 2015) (pretrial-detainee excessive-force claims judged by an objective standard)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference requires subjective knowledge of substantial risk)
Bell v. Wolfish, 441 U.S. 520 (U.S. 1979) (conditions of confinement and when restrictions amount to punishment)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility pleading standard under Rule 12(b)(6))
Mata v. Saiz, 427 F.3d 745 (10th Cir. 2005) (subjective prong requires official to know and disregard risk)
Self v. Crum, 439 F.3d 1227 (10th Cir. 2006) (defining objectively serious medical need)
Clark v. Colbert, 895 F.3d 1258 (10th Cir. 2018) (reiterating two-prong deliberate indifference test)
Colbruno v. Kessler, 928 F.3d 1155 (10th Cir. 2019) (applied Kingsley in a conditions-of-confinement/punishment context)