Valerie McCann v. Ogle County, Illinois, 909 F.3d 881

Background

Patrick McCann was discharged from hospital after severe burns, taken to Ogle County jail with discharge papers and prescriptions; jail staff and nurse Cindy Mongan provided intensive care and frequent checks.
Contract physician Dr. Stephan Cullinan prescribed methadone; on April 27 he ordered 60 mg twice daily (later reduced to 40 mg twice daily), a dose the district court found excessive and ultimately lethal.
Nurse Mongan administered methadone per Dr. Cullinan’s orders and performed frequent monitoring and wound care; she did not take vital signs in the early morning before McCann was found unresponsive and died from methadone overprescription.
McCann’s estate sued under 42 U.S.C. § 1983 against the doctor and his employer (who settled) and against Nurse Mongan, Sheriff Beitel, Captain Kerwin (individual capacity) and Ogle County (Monell claim).
The district court granted summary judgment for the remaining defendants under the deliberate-indifference standard; the Seventh Circuit reviewed the record under Miranda’s objective-reasonableness standard and affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether individual defendants violated pretrial detainee’s Due Process rights by providing constitutionally inadequate medical care	McCann’s estate: Mongan’s failure to check vitals and administration of methadone amounted to unconstitutional medical care	Defendants: Mongan followed physician orders; nonmedical officials reasonably deferred to medical staff; conduct was not objectively unreasonable or purposeful/reckless	Court: No; record lacks evidence of purposeful/knowing/reckless conduct and the care was objectively reasonable
Whether a nurse must second-guess a physician’s dosage orders when those orders risk harm	Estate: Nurse should have recognized and refused dangerous dosage	Nurse: Licensed practical nurse may rely on physician’s medical judgment absent obvious risk	Court: Nurse reasonably relied on physician; no obvious risk shown that would make reliance unreasonable
Whether Sheriff Beitel and Captain Kerwin are liable for municipal-type claims based on their roles	Estate: Officials’ decision to house McCann rather than hospital reflected cost-saving policy causing injury	Defendants: Officials deferred to Dr. Cullinan’s medical judgment and had no notice of inadequate care or policy favoring cost savings	Court: No Monell liability; no evidence of a policy, custom, or official action causing the death
Standard governing pretrial detainee medical claims	Estate: Deliberate indifference (or equivalent) supports liability	Defendants: After Miranda, the proper test is objective reasonableness and requires more than negligence	Court: Applies Miranda/Kingsley two-step framework: mens rea (purposeful/knowing/reckless) and objective reasonableness; estate’s claims fail under that framework

Key Cases Cited

Miranda v. County of Lake, 900 F.3d 335 (7th Cir. 2018) (adopts objective-reasonableness framework for pretrial detainee medical claims)
Kingsley v. Hendrickson, 135 S. Ct. 2466 (2015) (Fourth Amendment excessive-force standard is objective)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate-indifference standard for inmates requires subjective knowledge of risk)
Monell v. Dep’t of Social Services of New York, 436 U.S. 658 (1978) (municipal liability requires an official policy or custom causing the injury)
Darnell v. Pineiro, 849 F.3d 17 (2d Cir. 2017) (due-process § 1983 claims require mens rea greater than negligence)
Berry v. Peterman, 604 F.3d 435 (7th Cir. 2010) (nurses may defer to physician orders but not blindly if order obviously harmful)
Dixon v. County of Cook, 819 F.3d 343 (7th Cir. 2016) (Monell and inadequate-care principles; negligence insufficient for § 1983 due-process claim)
City of Canton v. Harris, 489 U.S. 378 (1989) (municipal liability principles for failure to train or supervise)
Arnett v. Webster, 658 F.3d 742 (7th Cir. 2011) (nonmedical officials may reasonably rely on medical staff’s expertise)
Kentucky v. Graham, 473 U.S. 159 (1985) (official-capacity suits are treated as suits against the governmental entity)