Jerry L. Gentry v. Gean Seiger, LeRoy Martin, and Jerry Maness

Summary

The document is a memorandum opinion and order in a pro se 42 U.S.C. § 1983 action brought by Jerry L. Gentry against officials of the Columbia County Detention Center. The remaining claim concerns alleged deliberate indifference to serious medical needs, including injuries, chest pain, dizziness, and high blood pressure. The court considers the defendants’ second motion for summary judgment and states that it grants the motion in part and denies it in part.

Holdings

1. A verified complaint may be treated as the equivalent of an affidavit for summary-judgment purposes, and Gentry's verified allegations could create factual disputes where the record contained no medical records and competing verified statements.
2. Summary judgment was inappropriate concerning the objective seriousness of Gentry's ankle injury because the evidence created a factual dispute over whether the injury was sufficiently obvious to require medical attention. The court assumed, for purposes of the opinion, that Gentry's other claimed injuries and ailments were objectively serious.
3. Genuine disputes of material fact precluded summary judgment for Seiger on Gentry's individual-capacity deliberate-indifference claim.
4. Martin and Maness were entitled to summary judgment because Gentry failed to establish personal involvement or direct responsibility for the alleged denial of medical care; supervisory liability cannot rest solely on respondeat superior.
5. Gentry's official-capacity claims failed because he did not show that the alleged denial of medical care resulted from an official policy, custom, or practice of Columbia County.
6. Seiger was not entitled to summary judgment on qualified-immunity grounds because genuine disputes existed concerning predicate facts material to whether she violated Gentry's clearly established right to adequate medical care.

Questions Presented

1. Whether genuine disputes of material fact precluded summary judgment on Gentry's individual-capacity deliberate-indifference claim against Seiger.
2. Whether Gentry presented sufficient evidence that his alleged ankle injury and other symptoms constituted objectively serious medical needs.
3. Whether Gentry presented sufficient evidence that Seiger knew of and deliberately disregarded his serious medical needs.
4. Whether Martin and Maness could be liable under 42 U.S.C. § 1983 without evidence of personal involvement or direct responsibility for the alleged denial of medical care.
5. Whether Gentry established an official-capacity claim based on a county policy, custom, or practice.
6. Whether Seiger was entitled to qualified immunity at the summary-judgment stage.

Disposition

other