Eighth Circuit Upholds Dismissal of Minnesota Prisoner Medical Deliberate Indifference Lawsuit
On November 24, 2014, the Eighth Circuit U.S. Court of Appeals issued a ruling that affirmed a district court order granting summary judgment to Olmstead County, Minnesota defendants in a lawsuit in which the family of a deceased prisoner had sued for deliberate indifference to his serious medical needs.
Cody Laganiere was found dead in his cell at the Olmstead County Adult Detention Center (ADC) on September 24, 2010. Subsequent medical tests indicated that Laganiere died from a methadone overdose. One week prior to his death, Laganiere was prescribed methadone by jail medical staff, after which time another prisoner informed jail officials that Laganiere would "slur and drool" after he took his medication, and suggested that jail guards regularly check on Laganiere due to his "changes in behavior."
Mary Mauseth, a guard at ADC, testified she checked on Laganiere every thirty minutes and that he was "behaving and sleeping normally." On the day of his death, Mauseth said that Laganiere refused 7:00 a.m. breakfast call and did not leave his cell to get his meds. Mauseth further detailed that she continued to check on him every half hour and found "nothing unusual" until she noticed at about 10:30 a.m. that he had been sleeping in the same position for an extended period of time. When she received no answer from Laganiere, she shook his shoulder and found him unresponsive. Attempts to revive Laganiere proved unsuccessful and he was pronounced dead.
While methadone toxicity was listed as the cause of death, acute pneumonia and major depression were listed as contributing factors.
The trustee of Laganiere's estate brought suit against ADC and several employees alleging deliberate indifference to Laganiere's medical needs. The trustee contended that Mauseth and other jail staff knew Laganiere suffered serious side effects from methadone but "disregarded the issue." On motion by the ADC defendants, the district court granted summary judgment, finding no evidence to support the claims, and dismissed the suit. The trustee appealed.
The Eighth Circuit affirmed, however, stating that it found "no support" in the record for the trustee's allegations. There was no evidence that the prisoner who told staff to check on Laganiere ever told that information to Mauseth, nor was there any evidence to show that Mauseth was ever present to see Laganiere "slur and drool."
The appellate court noted that Mauseth's actions were appropriate based on what she knew, and that she routinely checked on Laganiere, who exhibited nothing "which would have caused Mauseth to recognize the need for a doctor's attention." Because there was no known risk that Mauseth deliberately disregarded, summary judgment was correctly granted to defendants, the court said.
The Eighth Circuit also dismissed the trustee’s argument that Mauseth's supervisors were at fault for "failure to properly supervise and train" her. "Considering the facts before us, the trustee fails to make this showing," the court wrote. "The record contains no evidence regarding [ADC officials'] supervision or training of Mauseth."
Consequently, the Eight Circuit upheld the dismissal of all claims against ADC and Mauseth "because the trustee has not shown that any officer deliberately disregarded Laganiere's medical needs in violation of the Eighth Amendment." See Laganiere, Trustee for the heirs and next of kin of Cody Patrick Laganiere v. The County of Olmstead, Olmstead County Detention Center, et al., No, 14-1088 (8th Cir. 2014).