Ryan Crum v. Brent Miller, Joey Richardson, Tyson Abbott, and Sherry Patton

Summary

The United States District Court for the Southern District of Indiana grants Nurse Sherry Patton's unopposed motion for summary judgment on Ryan Crum's Fourteenth Amendment claim concerning allegedly inadequate medical care for dental injuries sustained while detained. The Court concludes that the evidence does not show that Patton acted purposefully, knowingly, or recklessly, or that her response was objectively unreasonable. Patton is terminated as a defendant, while the claims against the remaining defendants continue, with further proceedings and potential settlement discussions directed.

Holdings

1. A pretrial detainee's unconstitutional medical-care claim is evaluated under the objective-unreasonableness framework, requiring proof of an objectively serious medical need, a volitional act concerning that need, objectively unreasonable conduct under the circumstances, and purposeful, knowing, or perhaps reckless conduct with respect to the risk of harm.
2. Patton was entitled to summary judgment because the designated evidence did not establish objectively unreasonable conduct or purposeful, knowing, or reckless action with respect to Crum's medical needs.

Questions Presented

1. Whether Nurse Patton was entitled to summary judgment on Crum's Fourteenth Amendment claim that she provided constitutionally inadequate medical care.
2. Whether the undisputed evidence showed that Patton's conduct was objectively unreasonable and that she acted purposefully, knowingly, or recklessly with respect to the risk of harm.

Disposition

other