Summary
The United States Court of Appeals for the Eleventh Circuit reviews a summary judgment ruling in a 42 U.S.C. § 1983 action arising from the death of an incarcerated person who allegedly received inadequate medical care at the Walker County Jail. The court holds that the evidence could permit a jury to find that Walker County adopted and maintained a deliberately indifferent policy of contracting with an incompetent healthcare provider, notwithstanding Alabama law assigning jail healthcare responsibilities to the sheriff. The court reverses the grant of summary judgment for Walker County and remands for further proceedings.
Topics
Practice areas
Questions Presented
- Whether Alabama law barred Walker County from liability under § 1983 for a policy of contracting for and maintaining allegedly inadequate inmate medical care.
- Whether the evidence created a genuine dispute of material fact as to whether Walker County maintained a policy or custom, acted with deliberate indifference, and directly caused the deprivation of Mitchell Smothers's Eighth Amendment right to adequate medical care.
- Whether summary judgment was proper when a reasonable jury could find that Walker County's continued contract with Preemptive caused or contributed to the inadequate medical care and death.
Holdings
- A county may be liable under Monell when it adopts, maintains, or permits a policy or custom of contracting for inadequate jail medical care and that policy directly causes a constitutional deprivation; the county cannot avoid liability merely because a private healthcare provider performed the medical services.
- To prevail on a custom-or-policy Monell theory, a plaintiff must show a constitutional violation, a municipal policy or custom that reflects deliberate indifference to the constitutional right, and a direct causal link between the policy or custom and the violation; the evidence here was sufficient for a reasonable jury to find all three elements.
- Alabama Code §§ 14-6-19 and 14-6-20 do not absolve a county of Monell liability for establishing or maintaining a policy that directly causes inmates to receive constitutionally inadequate medical care.
- Summary judgment for Walker County was improper because the evidence, viewed in Smothers's favor, would allow a reasonable jury to find that the county's policy caused deliberate indifference to Mitchell's serious medical needs and contributed to his death.
Key quotations
“And because a reasonable jury could also determine that the county’s alleged policy resulted in Mitchell’s death, Smothers has plausibly asserted that the county violated Mitchell’s Eighth Amendment right to be free from deliberate indifference to his medical needs.” (3-4)
“Putting it all together, then, to establish a Monell claim under a custom or policy theory, Smothers must show “(1) that [Mitchell’s] constitutional rights were violated; (2) that [the county] had a custom or policy that constituted deliberate indifference to that constitutional right; and (3) that the policy or custom caused the violation.”” (16-17)
“The county’s deliberate decision to continue and then renew its contract with Preemptive under these circumstances, like Broward County’s decision in Ancata to require its jail’s prisoners to obtain court orders to receive necessary medical treatment, was an official policy to knowingly provide inadequate medical care to the people in the Jail.” (20-21)
“Rather, a county must not establish a policy that directly causes inmates to receive inadequate healthcare.” (25-26)
Factual background
Walker County contracted with Preemptive Forensic Health Solutions to provide comprehensive medical services at the Walker County Jail, although Preemptive employed no physicians and allegedly provided substantially deficient care. The county renewed or continued the contract despite inmate deaths, complaints about inadequate care, evidence that physicians were not visiting as contractually required, and the elected sheriff's requests to terminate Preemptive. Mitchell Wayne Smothers entered the jail with serious medical conditions, including cirrhosis, hepatitis C, cellulitis, and nonhealing wounds, but was not seen by a physician and received inadequate treatment before dying of septic shock and multisystem organ failure. Expert testimony supported a finding that the deficient care directly contributed to his death.
Procedural history
Smothers sued Walker County, Preemptive Forensic Health Solutions, and Roger Childers under § 1983. She settled with Preemptive and Childers, leaving Walker County as the remaining defendant. The United States District Court for the Northern District of Alabama granted Walker County summary judgment on the ground that Alabama law imposed on the county only a duty to fund inmate medical care and therefore barred liability. The Eleventh Circuit reversed and remanded, holding that the record permitted a jury to find that the county adopted and maintained a policy causing constitutionally inadequate medical care.
Remand instructions
Vacate the district court's grant of summary judgment to Walker County and remand for further proceedings on Smothers's § 1983 claim.