Shawn Tolbert v. Nurse Deborah Quesenberry, et al.

Summary

The United States District Court for the Western District of Virginia grants the defendants’ motion for summary judgment in Shawn Tolbert’s 42 U.S.C. § 1983 action. The court holds that the record does not support a finding that jail medical, mental-health, or correctional personnel acted with deliberate indifference to Tolbert’s medical needs in violation of the Fourteenth Amendment.

Holdings

1. A pretrial detainee asserting deliberate indifference to medical needs must present evidence that he had a condition posing a substantial risk of serious harm, the defendant intentionally, knowingly, or recklessly acted or failed to act to address the risk, the defendant knew or should have known both of the condition and the unjustifiably high risk created by the conduct, and the detainee was harmed. Tolbert failed to produce evidence from which a reasonable jury could find these elements as to any defendant.
2. Defendants were entitled to summary judgment because no reasonable jury could find that Hunt, Moran, Keen, Cornett, Ferguson, or Quesenberry acted with deliberate indifference to Tolbert's medical needs.

Questions Presented

1. Whether the evidence created a genuine dispute of material fact that any defendant acted with deliberate indifference to Tolbert's serious medical needs in violation of the Fourteenth Amendment.
2. Whether the individual defendants were entitled to summary judgment on Tolbert's § 1983 claims.

Disposition

other