Summary
The Ninth Circuit reversed the district court's grant of summary judgment based on qualified immunity for a California Highway Patrol officer in a § 1983 action alleging deprivation of medical care under the Fourth and Fourteenth Amendments. The court held that a reasonable jury could find the officer acted unreasonably by failing to summon prompt medical assistance for an arrestee exhibiting severe distress following a serious single-vehicle collision, which ultimately resulted in a stroke. The decision clarifies that the duty to provide objectively reasonable medical care applies regardless of whether the injury was caused by police conduct, and remands the case for further proceedings.
Topics
Practice areas
Questions Presented
- Whether Officer Durazo violated the Fourth and Fourteenth Amendments by failing to provide objectively reasonable medical care to an arrestee.
- Whether qualified immunity shields Officer Durazo from liability under 42 U.S.C. §1983.
Holdings
- A jury could find that Officer Durazo's failure to summon prompt medical care violated the Fourth and Fourteenth Amendments, and therefore she is not entitled to qualified immunity.
- The district court's summary judgment granting qualified immunity is reversed; Officer Durazo is not entitled to qualified immunity because the duty to provide prompt medical care was clearly established.
Key quotations
“We hold that construing the facts in the light most favorable to D’Braunstein, a reasonable jury could find that Officer Durazo violated D’Braunstein’s constitutional rights by failing to summon prompt medical care, considering the serious nature of the collision and his evident symptoms of distress.” (at 9)
“The Constitution has been interpreted to require state actors to provide adequate medical care in certain circumstances when the government is confining a person or otherwise restricting his liberty.” (at 10)
Factual background
Steven D'Braunstein was involved in a serious single‑vehicle crash. Officer Samantha Diaz‑Durazo arrived, observed disorientation, slurred speech, sweating and poor balance, but did not call emergency medical services. She arrested him, transported him to jail, and only after a jail nurse refused admission did she take him to the hospital, where he was diagnosed with a stroke.
Procedural history
The district court granted summary judgment to Defendant Officer Durazo, finding no clearly established right to summon medical aid. The plaintiff appealed the qualified‑immunity ruling.
Remand instructions
The district court shall resume consideration of the state law claims and proceed with further proceedings on the §1983 claim.