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Tenth Circuit Reinstates Suit over Failure to Provide Medical Treatment to Oklahoma Arrestee/Prisoner

by Matt Clarke

On January 23, 2017, the Tenth Circuit Court of Appeals reversed in part a district court’s grant of summary judgment to an Oklahoma state trooper and jailers who failed to obtain medical care for a prisoner after mistaking a brain injury for intoxication. An amended appellate ruling resulted in the same findings.

Clyde Rife was sitting astride his motorcycle next to a road when he was approached by Oklahoma State Trooper Joe Jefferson. It became clear that Rife could not remember the date, time or what he had been doing in the town he just left. Jefferson noted evidence of an accident, including grass and marks on the motorcycle and on Rife’s clothing, and dried blood from Rife’s nose. Rife said he was okay and denied having had an accident or using drugs.

Jefferson administered tests and made observations that caused him to conclude Rife was intoxicated with pain killers. Those observations included constricted pupils, lethargy, nystagmus (uncontrolled eye movements), slurred speech, dizziness and Rife’s statement that he felt “floaty.”

Rife did not exhibit uneven dilation of the eyes, uneven tracking or resting nystagmus – which would be indications of a brain injury. Jefferson arrested Rife and took him to a jail run by the McCurtain County Jail Trust. During the trip, Rife groaned and complained of chest pain, head aches and feeling sick.

Rife was booked into the facility but not seen by medical personnel. Instead, he was placed in an observation cell for detoxification. He continued to complain of pain and, according to his cellmate, was in obvious need of medical attention but received none.

The following morning, Rife was released. He walked about 100 feet to a bail bondman’s office where he sat down; when he tried to get up, he collapsed unconscious. He was subsequently treated for a head injury resulting from the motorcycle accident.

Rife filed a federal civil rights suit pursuant to 42 U.S.C. § 1983 against the Oklahoma Department of Public Safety, Jefferson, the jail trust and two jailers alleging lack of probable cause to arrest him and deliberate indifference to his serious medical needs. The defendants filed motions for summary judgment which the district court granted. Rife appealed.

The Tenth Circuit held there was probable cause to arrest Rife, but it could be reasonably inferred from the evidence that Jefferson and/or jailers had been both deliberately indifferent to his serious medical needs and negligent. Aiding in that conclusion was a video recording from Jefferson’s patrol car which disproved the trooper’s claim that Rife never complained about pain or feeling sick. An affidavit from the cellmate also helped show that Rife complained of pain and requested medical attention while incarcerated.

The jail had destroyed video tapes showing Rife at intake, and he had sought sanctions for spoliation of evidence, which the district court denied. The Tenth Circuit upheld the denial because Rife had failed to preserve that issue and did not show bad faith by the defendants.

Therefore, the judgment of the district court was affirmed as to the denial of Rife’s wrongful arrest claims and reversed for his deliberate indifference to serious medical needs claims. The case was remanded for the lower court to determine whether Rife’s rights had been clearly established at the time, and whether a reasonable factfinder could find a causal link between the jail trust’s policies or customs and a violation of Rife’s constitutional rights. See: Rife v. Oklahoma Department of Public Safety, 846 F.3d 1119 (10th Cir. 2017).

A motion for rehearing en banc was denied, but an amended opinion was issued by the appellate court on April 12, 2017 that reached the same substantive conclusions. See: Rife v. Okla. Dep’t of Pub. Safety, 854 F.3d 637 (10th Cir. 2017), cert. denied. 

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Related legal case

Rife v. Oklahoma Department of Public Safety