Townsend v. Jefferson Co.
601 F.3d 1152 (11th Cir. Ala. 2010)
An inmate sued two sheriff’s deputies, arguing that their deliberate indifference to her serious medical condition led her to have a miscarriage while in jail. The inmate had used crack cocaine and smoked cigarettes every day of her pregnancy before being incarcerated. The inmate began experiencing abdominal pain and vaginal bleeding in her cell, and she alleged that she and her cell-mates called for help several times over an eight hour span before being attended to. The nurse determined that there was no emergency and the inmate was returned to her cell, where her condition allegedly worsened and she ultimately had the miscarriage. The district court denied the deputies’ summary judgment motion based on qualified immunity. The district court ruled that the inmate had presented evidence that the deputies violated the inmate’s Fourteenth Amendment rights by deliberate indifference to her serious medical need. The circuit court reversed and granted summary judgment to the deputies. Though the court noted that the inmate had shown a serious medical need, it held that to establish deliberate indifference, the inmate was required to show something beyond gross negligence. The inmate had not presented sufficient evidence to allow a reasonable jury to conclude that the deputies knew this was an emergency situation. The deputies knew that the nurse had examined the inmate and determined that the situation was not an emergency, there was no evidence suggesting that
the inmate’s condition was so dire that the lay deputies should have known that the medical
professional nurse had misjudged the severity of the situation, and there was insufficient
evidence to constitute a genuine issue of material fact regarding whether the deputies had
been advised that the inmate’s condition had worsened. Accordingly, the deputies were
entitled to qualified immunity, and thus summary judgment.