Medical care for inmate was not provided in this case


Marshawn Williams and his longtime girlfriend, Lavina Smith, got into a physical altercation at their Yazoo City, Mississippi home. A witness alerted both Smith’s family and police. Smith’s family arrived first. Outraged that Williams had been violent to his sister, Smith’s brother hit Williams on the side with either a bedrail or a metal pipe. The two men tussled over the object until Smith’s uncle intervened and separated them.

Police were not far behind. Sergeant Thompson and Officers Harris, Dean, and Banks of the Yazoo City Police Department arrived at the home a few minutes later and split up: Harris and Thompson went inside to speak with Smith, while Dean and Banks spoke with Williams on the porch. Williams told Dean and Banks that he had been drinking and that he and Smith had fought. He also told them that Smith’s brother assaulted him with a pipe.

He lifted his shirt to show Dean where he had been hit, revealing superficial scratches. During that conversation, Williams laid down on the porch as if trying to sleep. Harris joined the group outside, handcuffed Williams, and informed him that he was under arrest for domestic violence.

Smith, who observed the arrest from the porch, recalls that Williams struggled to walk and collapsed on his way to the police car. The officers say that he was passively resisting arrest by forcing them to carry him to the vehicle. Harris sprayed mace in Williams’s eyes and the officers loaded him into the police car.

The officers brought Williams to the Yazoo County Detention Center. Williams was in and out of consciousness during booking. At one point, he urinated on himself and slumped out of his chair to the ground. He did not cooperate with the officers’ requests for personal information. Contrary to jail policy, no officer screened him for medical needs.

Dean and Banks escorted Williams to his cell. Again, Williams needed assistance walking. Three detainees overheard Williams ask Dean and Banks for help during the walk to his cell. One recalls Williams telling the officers, “I need my medical assistance, and I can’t breathe,” and another heard Williams say “I need some help. I need y’all to call my people, my family so I can get my medication.” The third similarly remembers Williams requesting medical help. The officers did not respond to Williams’s pleas.

Meanwhile, Officer Patrick Jaco called Smith to ask if Williams was sick or on any medication. Smith passed the phone to Williams’s mother, Donnie, who said that she would come to the jail to discuss the matter. Donnie was worried because she knew that Williams had been in a scuffle back at the house and likely needed medical attention.

At the jail, Donnie, her daughter, and her nephew spoke to Harris, Jaco, Dean, Banks, and Officer Sharon VanCleave. Jailer Tracey Langston, who was sitting at a nearby desk, was also present for the conversation. Donnie told the group that Williams was not currently on any medication. She also told them that Williams grabbed his side and fell over before his arrest. She explained that Williams’s blood does not clot normally so that if he got hurt in any kind of way he would just bleed.

Williams’s sister chimed in, noting that “He could die!” Banks responded that Williams had passed out twice in front of them, but Dean dismissed his concerns, suggesting that Williams was merely being uncooperative to avoid arrest. The officials did not take any action in response to this information.

Once in his cell, Williams repeatedly called for his mother and for medical attention. He was unable to stand or use the toilet on his own. His cellmate propped him into a seated position against a wall, and he lost consciousness there.

For two to three hours, Williams’s fellow detainees banged on their cell doors and repeatedly yelled to Langston that Williams was having a medical emergency. Langston asked them to quiet down and told them that she could not do anything until her superior returned to the jail. She did not check on the detainees hourly, as required by prison policy.

Around 2:15 a.m., officers found Williams dead in his cell. The autopsy report concluded that Williams had died of a laceration to his liver and extensive internal bleeding. It also noted blunt force injuries on the left side of his torso.

Williams’s surviving family sued Yazoo City, the Yazoo City Police Department, and the officers and jailer involved in his arrest and detention. They contend that the officials violated Williams’s federal rights by falsely arresting him, using excessive force, and wrongfully denying him medical care. They further assert that the City violated his federal rights by inadequately training its employees and maintaining an unconstitutional policy of the same. Finally, they sued the officials in their official capacities for related state law torts, including an analogous denial-of-care claim.

The City and individual defendants moved for summary judgment. The district court dismissed many of the claims but determined that the federal and state denial-of-care claims and the claims against the City should be submitted to a jury. In rejecting the officials’ qualified immunity defense at summary judgment, the district court found numerous fact issues that, if resolved in the plaintiffs’ favor, would establish their liability on the federal denial-of-care claim. It did not, however, consider whether that constitutional violation was clearly established at the time of Williams’s death.

Believing that the entire suit should have been dismissed, the defendants appealed.


A. Jurisdiction

Because qualified immunity insulates officials from the burdens of litigation, we can review the federal denial-of-medical care claim against the officials in their individual capacities. Yazoo City’s appeal is different. Municipalities do not enjoy qualified immunity so the denial of summary judgment to the City is not immediately appealable. We lack jurisdiction over the state law denial-of-medical-care claim for the same reasons.  Accordingly, at this time we consider only the individual defendants’ qualified immunity appeal.

B. Constitutional violation

The Constitution imposes a duty on the state to provide for the safety and wellbeing of the people it incarcerates. See DeShaney v. Winnebago Cnty. Dep’t of Soc. Servs., 489 U.S. 189 (1989). For people already convicted of a crime, this duty stems from the Eighth Amendment’s prohibition on cruel and unusual punishment. For those like Williams, who have not yet faced trial, it stems from due process instead.

The state’s obligation is the same in both contexts: It must provide for detainees’ “basic human needs, including “food, clothing, shelter, medical care, and reasonable safety.”

The U.S. Supreme Court in Farmer v. Brennan, 511 U.S. 825 (1994), said that the Fourteenth Amendment bars law enforcement from responding to a detainee’s serious medical needs with deliberate indifference. To prove deliberate indifference, Williams’s survivors must show that the defendants knew that he faced a substantial risk of serious harm and failed to take reasonable measures to abate that risk.

The knowledge inquiry is subjective. But the reasonableness question is objective: It turns on whether the officials’ response to a known risk was reasonable as a matter of law.

B1. Dean and Franks

Taking Williams’s allegations as true, Dean and Banks were aware of a substantial risk to Williams’s health. Williams’s family was so concerned about him that they came to the station to tell law enforcement about his medical vulnerability. Williams’s mother informed them that Williams suffered from a preexisting and life-threatening blood clotting condition that would cause him to bleed internally if he was “hurt in any kind of way.” And Williams’s sister reiterated to them how serious the condition was, explaining that Williams “could die” if injured.

In addition to knowing of Williams’s diagnosis, Dean and Banks knew that Williams was hurt. When they first talked to Williams, he told them that he had been hit in the side with a metal pipe. Williams’s mother later reminded them that he “grabbed his side and fell over” before his arrest. Dean and Banks also witnessed Williams struggling to walk and were aware that he passed out at least twice during his arrest and booking.

If any doubt remained about Williams’s need for care at that point, it was eliminated when Williams told Dean and Banks that he could not breathe and asked them for medical assistance while they escorted him to his cell.

If these allegations are proven, this is not a close case: Williams’s diagnosis, symptoms, and requests for help notified Dean and Banks of a significant risk that he was bleeding internally.

B2. Harris, Jaco, and VanCleave

Like Dean and Banks, they were informed by Williams’s family that he had a blood clotting condition that made any injury potentially fatal. They also saw Williams lose consciousness during booking. Unlike Dean and Banks, they did not know exactly how Williams had been injured—they only knew from his mother that he “grabbed his side and fell over.”

Observing Williams’s behavior alone may not have been enough to establish the defendants’ knowledge. We have granted qualified immunity in Lessard when law enforcement misconstrued the symptoms of a serious medical condition for intoxication, or a less serious illness in Collier. But in those cases, the officials had to assess the risk to the detainee’s health based on symptoms alone. We afford law enforcement latitude in those situations recognizing that they do not have the training of a medical professional.

Here, however, the officers’ knowledge of risk was based on much more than just symptoms: They also knew that Williams had a life- threatening condition and had suffered trauma of the type that would trigger that condition.

B3. Langston

Langston also had knowledge of, yet ignored, the risk to Williams’s life. On the night Williams died, Langston was charged with checking on the detainees hourly and providing them food and water. Williams’s fellow detainees say that after he was brought to his cell in bad condition, they tried to get Langston’s attention by beating on their cell doors for two to three hours and repeatedly yelling things like “Help!” and “We have an emergency! We need medical attention! We need a doctor!” Such a total failure to act was unreasonable.

B4. Failure to act

Knowledge of risk, of course, is not enough for liability. Williams’s survivors must also show that the officials failed to take reasonable measures to abate that risk.

We have repeatedly held that refusing to treat a detainee and ignoring a detainee’s complaints are unreasonable responses to a known medical risk. See Perniciaro and Nerren. Yet that is exactly what the defendants did.

Despite knowing of Williams’s injury and condition, they ignored his requests for help. In fact, they did not do anything to make sure that he was okay. They did not question him about his medical condition, move him to an observational cell, summon medical assistance, or even check on him in the hours following his arrest.

The defendants believe that their response was reasonable because Dean examined Williams’s abdomen prior to his arrest and Jaco called Williams’s family to ask about his medical needs. The problem is that both actions occurred before their conversation with Williams’s family. At that point, only Dean and Banks knew that Williams had been hit with the pipe and none of the defendants knew about his clotting disorder. They also had not yet observed him struggling to walk and passing out during booking. Once they learned of the combination of Williams’s preexisting condition and his trauma, they knew of the risk to his life and were obligated to take reasonable action to abate that risk.

C. Clearly established

Officers and jailers have long had notice that they cannot ignore a detainee’s serious medical needs. It is clearly established that an official who refuses to treat or ignores the complaints of a detainee violates their rights. See Sims.

In Easter, we denied qualified immunity to prison officials who knew that Easter had a preexisting, serious heart problem but refused him treatment when he presented with severe chest pain.

In Nerren, we denied qualified immunity to officers who rejected Nerren’s request for medical assistance despite knowing that he was involved in a car accident.

The facts of this case fit comfortably within Easter’s and Nerren’s teaching that law enforcement may not ignore reports that a detainee is suffering a serious medical emergency, particularly when those reports are backed by knowledge of a preexisting condition or trauma.

Here, the reports came from numerous sources: Williams, his family, and his fellow detainees. At the time of Williams’s death, it was beyond debate that the defendants’ total failure to respond to his medical needs was unconstitutional.

We DISMISS Yazoo City’s appeals for lack of jurisdiction, AFFIRM the district court’s denial of qualified immunity to the individual defendants on the federal denial-of-medical-care claim, and REMAND for further proceedings.