Angie Davis v. St. Louis County, Missouri, et al.

Summary

The United States District Court for the Eastern District of Missouri addresses motions to dismiss claims arising from the death of a detainee, Dwight Williams, in the St. Louis County Jail. The court denies dismissal of the deliberate-indifference claims against nurses David Dooley and Janie Stephens, but dismisses claims against the remaining individual defendants and St. Louis County, including municipal-liability, supervisory-liability, ADA, and Rehabilitation Act claims. The court also considers a service-of-process challenge by defendant Lisa Maxwell.

Holdings

1. The complaint plausibly alleged deliberate indifference claims against Dooley and Stephens because it alleged that Williams had a serious medical need, that both defendants knew of his Suboxone prescription and withdrawal, and that they intentionally failed to provide the prescribed treatment.
2. The complaint failed to state a deliberate-indifference claim against Kelly Wilkens, Dawn Davis, or Valerie Nelson because it did not specifically allege that they knew of Williams's serious medical need or his Suboxone prescription.
3. The complaint failed to state a § 1983 municipal-custom claim against St. Louis County.
4. The complaint failed to state failure-to-train, failure-to-supervise, or failure-to-discipline claims against St. Louis County, Dawn Davis, Valerie Nelson, and Lisa Maxwell.
5. The ADA and Rehabilitation Act claims failed because the complaint alleged inadequate medical treatment, not discrimination based on disability or denial of services because of disability.
6. Maxwell did not waive her insufficient-service defense by asserting it in her proposed answer, but the court granted plaintiff fourteen days to properly serve her and file an executed proof of service.

Questions Presented

1. Whether the complaint plausibly alleged that David Dooley and Janie Stephens were deliberately indifferent to Williams's serious medical needs by failing to provide his prescribed Suboxone.
2. Whether the complaint plausibly alleged municipal liability against St. Louis County based on an unconstitutional policy, custom, or failure to train or supervise.
3. Whether the complaint plausibly alleged individual supervisory liability against St. Louis County, Dawn Davis, Valerie Nelson, and Lisa Maxwell for failure to train, supervise, or discipline.
4. Whether the ADA and Rehabilitation Act claims were actionable where the alleged misconduct consisted solely of inadequate medical treatment rather than disability-based discrimination.
5. Whether Lisa Maxwell waived or established a defense based on insufficient service of process, and whether plaintiff should receive additional time to effect proper service.

Disposition

other