Summary
This Seventh Circuit per curiam opinion dismisses an interlocutory appeal by a correctional officer who was denied qualified immunity in a § 1983 action alleging he failed to provide adequate medical care to a detainee who died in jail. The appellate court held that it lacks jurisdiction because the qualified immunity determination depends on resolving disputed material facts regarding the officer's observations and duties, which cannot be reviewed at this stage. The court emphasizes that interlocutory appeals denying qualified immunity are strictly limited to pure questions of law.
Topics
Practice areas
Questions Presented
- Whether the appellate court has jurisdiction to review the district court’s denial of qualified‑immunity on interlocutory appeal grounds
- Whether correctional officers owe a constitutional duty to provide adequate medical care to detainees in medical units
Holdings
- The Seventh Circuit lacks jurisdiction to entertain the interlocutory appeal because the qualified‑immunity issue turns on disputed facts, and therefore the appeal is dismissed for lack of appellate jurisdiction.
Key quotations
“We lack jurisdiction on an interlocutory appeal to review a denial of qualified immunity when the district court’s decision, or the appellant’s argument, turns on disputes of material fact.” (at 9)
Factual background
Dalynn Kee, detained at the Macon County Jail, suffered opioid withdrawal and later severe dehydration. Correctional officer Michael Whitsel was responsible for monitoring her in a medical unit via video feed and periodic checks. Despite observing numerous vomits, falls, and a period of unresponsiveness, Whitsel failed to notify medical staff. Kee died later that evening.
Procedural history
The district court denied Whitsel’s motion for summary judgment, finding genuine issues of material fact as to whether his conduct violated the Fourteenth Amendment. Whitsel appealed the denial, asserting qualified immunity, but the appellate court held the appeal was not appealable because the issue depended on disputed facts.