Jail Medical Care and Deliberate Indifference Cases

Sligh v. City of Conroe

No. 22-40518 (5th Cir. 2023) · Nov 21, 2023

While siccing a police dog on a suicidal woman who was not suspected of any crime and posed no threat to officers constituted excessive force, the officer was entitled to qualified immunity because the right was not clearly established under the specific circumstances, which involved active resistance followed by unintentionally prolonged canine force.

Zavala v. Harris County

No. 22-20611 (5th Cir. 2023) · Nov 21, 2023

Affirmed dismissal of Monell claims against Harris County and grant of qualified immunity to a jailer on excessive force claims arising from use of hog-tie restraints on a pretrial detainee, holding that the use of hog-ties was not clearly established as unconstitutional where the detainee exhibited disorderly and self-injurious behavior.

Kelson v. Clark

No. 20-10764 (5th Cir. 2021) · Jun 17, 2021

Paramedics who refused to treat a visibly injured, homeless, mentally ill man — instead harassing and laughing at him — were not entitled to qualified immunity on a failure-to-provide-medical-care claim after the man died from untreated head trauma in custody.

Roque v. Harvel

993 F.3d 325 (5th Cir. 2021) · Apr 1, 2021

An officer was not entitled to qualified immunity where he shot and killed a suicidal man during a mental health crisis, because a jury could find the officer's continued firing after the initial shot was objectively unreasonable.

Sanchez v. Young County

956 F.3d 785 (5th Cir. 2020) · Apr 22, 2020

Summary judgment for the county on a conditions-of-confinement claim was reversed where evidence showed the jail had a persistent pattern of failing to complete mandatory intake screenings, and a pretrial detainee died of a drug overdose after jailers put her in a cell to 'sleep it off' without completing suicide screening or medical intake forms.

Rich v. Palko

920 F.3d 288 (5th Cir. 2019) · Apr 3, 2019

Officers were entitled to qualified immunity when they used force to transport an incapacitated person with severe mental disabilities to a psychiatric facility, where the person's caretaker had called 911 requesting police assistance with the transport.

Westfall v. Luna

903 F.3d 534 (5th Cir. 2018) · Sep 13, 2018

Reversed summary judgment on false arrest claims where fact issues existed on probable cause; affirmed qualified immunity on excessive force (de minimis injury from assisting officer), First Amendment retaliation (force motivated by conduct not speech), denial of medical treatment (45-minute delay not deliberately indifferent), and failure to train claims against the City.

Skyy v. City of Arlington

No. 17-10529 (5th Cir. 2017) · Nov 9, 2017

Pro se plaintiffs' § 1983 claims against the city were dismissed because they relied on a respondeat superior theory—that city officers violated city personnel manual policies—rather than identifying a municipal policy or custom that was the moving force behind the alleged constitutional violations.

Carroll v. Ellington

800 F.3d 154 (5th Cir. 2015) · Aug 26, 2015

Deputies were entitled to qualified immunity on unlawful search and seizure claims and most excessive force claims arising from a fatal confrontation with a paranoid schizophrenic in his home, but not on excessive force claims for force used after the suspect was subdued and ceased resisting.

Taylor v. Barkes

575 U.S. 822 (2015) · Jun 1, 2015

Officials were entitled to qualified immunity because no clearly established law required the specific suicide-screening procedures the plaintiff claimed the Constitution demanded.

Lago-Planas v. Crocker

No. 3:09-CV-2075-G-BK (N.D. Tex.) · Mar 15, 2011

Officers were entitled to summary judgment on false arrest, excessive force, and denial of medical care claims where the evidence showed probable cause existed, force was reasonable, and the plaintiff's injuries did not require immediate medical treatment.

Erickson v. Pardus

551 U.S. 89 (2007) · Jun 4, 2007

Rule 8(a)(2) requires only a short and plain statement of the claim, not specific facts, and a pro se complaint must be liberally construed and held to less stringent standards than a pleading drafted by a lawyer.

Palo ex rel. Estate of Palo v. Dallas County

No. 3:05-CV-0527-D (N.D. Tex. 2006) · Dec 15, 2006

A pretrial detainee's estate could proceed to trial on a Fourteenth Amendment conditions-of-confinement claim where the county jail failed to provide adequate medical care to a detainee with serious medical conditions, resulting in his death.

Tarver v. City of Edna

410 F.3d 745 (5th Cir. 2005) · May 25, 2005

Officers were entitled to qualified immunity on unlawful arrest and handcuffing claims during a custody dispute, but genuine issues of material fact precluded qualified immunity on excessive force claims where an officer allegedly slammed a police car door on a handcuffed detainee's foot and head.

United States v. Lugo

289 F. Supp. 2d 790 (S.D. Tex. 2003) · Oct 17, 2003

Denied motion to suppress statements made by a defendant who was questioned as part of the BORCAP program at a county jail, finding that Miranda warnings were properly administered and that the defendant's waiver of his right to counsel was knowing and voluntary.

Siglar v. Hightower

112 F.3d 191 (5th Cir. 1997) · May 8, 1997

A prisoner's bruised and sore ear lasting three days constituted a de minimis injury insufficient to support an Eighth Amendment excessive force claim or to meet the physical injury requirement of the Prison Litigation Reform Act for mental or emotional suffering claims.

City of Canton v. Harris

489 U.S. 378 (1989) · Feb 28, 1989

A municipality can be liable under § 1983 for failing to train its employees when the failure to train amounts to deliberate indifference to the constitutional rights of persons the employees encounter.