Tressler v. Centre County
1:24-cv-00456
M.D. Penn.Dec 5, 2024Background
- Jessica Tressler, detained at Centre County Correctional Facility (CCCF) in April 2022, alleges serious injury due to inadequate medical care during her incarceration.
- Tressler claims that correctional and medical staff repeatedly dismissed her worsening medical complaints, leading to severe complications requiring heart valve replacement surgery.
- She filed suit under 42 U.S.C. § 1983, asserting federal constitutional violations (Fourteenth Amendment) and state law claims, against Centre County, individual correctional officers, medical staff, and PrimeCare Medical.
- County defendants moved to dismiss, arguing failure to state claims, entitlement to qualified immunity, lack of policy-level responsibility, and improper monetary demands.
- The court’s decision addresses only the County defendants’ motion as to federal claims (not the medical provider PrimeCare or unnamed defendants), evaluating both individual and municipal liability.
- Plaintiff was allowed an opportunity to amend certain claims, while some claims and parties were dismissed outright.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Denial of Medical Care (14th Amendment) | County officials were deliberately indifferent to Tressler's serious medical needs, resulting in harm | Tressler was seen by medical staff; non-medical officers relied on provider judgment; no deliberate indifference | Claims allowed against Officers Vangorder, Rupert, Quigley, Napoleon; dismissed as to Medford |
| Qualified Immunity (Individual Defendants) | Officers not entitled; right to adequate care is clearly established | Qualified immunity protects them, especially on failure-to-protect claims | Qualified immunity on failure-to-protect (all), but not yet on denial-of-care except Medford |
| Monell Liability (County) | County’s policies/customs showed deliberate indifference to inmate health | No specific policy/custom identified; PrimeCare was responsible for medical care | Sufficiently pled to proceed; contract with PrimeCare does not absolve County |
| Specific Monetary Demand | Plaintiff entitled to demand specific sum | Demand is improper | Demand for $5 million struck from complaint |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (deliberate indifference to serious medical needs violates the Eighth Amendment)
- Monell v. Dep't of Soc. Servs., 436 U.S. 658 (municipalities not liable under § 1983 for employees’ actions on a respondeat superior theory; must show policy/custom)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleading sufficiency)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must show factual entitlement to relief)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity—two-prong analysis for constitutional claims)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference is subjective standard—knowledge and disregard of risk)
- City of Revere v. Massachusetts General Hospital, 463 U.S. 239 (pretrial detainees have at least same right to medical care as convicted prisoners)