Arrestee Dies in a Jail with No Medical Staff; Eleventh Circuit Reverses Dismissal
by Ed Lyon
On April 3, 2019, the Court of Appeals for the Eleventh Circuit reversed a district court’s dismissal of a civil rights case concerning the death of a jail detainee.
Almus Taylor, 38, was arrested by Alabama State Troopers for drunk driving on November 16, 2013, after wrecking his truck. He refused treatment by paramedics at the scene of the accident because they would not let him bring his two dogs with him in the ambulance. Taylor was then taken to the Covington County jail, and the troopers told jail staff he had been “medically cleared” for admission based on his refusal of treatment.
After being booked, Taylor told the jailers “he [was] all busted up from [a] car wreck,” which was entered in the facility’s admission log. He was scratched, had visible injuries and had to be assisted when walking to a holding cell. During the night, Taylor repeatedly told jailers he was “broke up” inside and “dying,” while moaning in pain. They reportedly told him to “shut up,” and he finally obliged them by dying after the jail’s nurse arrived in the morning and he was en route to a hospital in an ambulance. It was later discovered that he had a lacerated liver, broken ribs, a punctured lung and internal bleeding.
Bonnie Edward Taylor filed a civil rights complaint in federal court for violation of his son’s constitutional rights and pendant state law violations. The district court dismissed the suit, granting summary judgment after finding the jailers enjoyed qualified immunity as well as state-agent immunity for the pendant claims under Alabama Code § 14-6-1, which is a conditional statute that provides immunities to sheriffs and jailers. An appeal was taken.
After reviewing the case, the Eleventh Circuit found genuine issues of material fact in dispute regarding Taylor’s injuries. The state troopers’ statement that he had been “medically cleared” for admission to the jail, contrary to his painful moans and pleas for help, conflicted to the extent that a reasonable jury could conclude the jailers should have known Taylor needed medical care.
The jailers’ deliberate indifference to Taylor’s condition was evidenced by their “willful disregard of what they heard and observed during the night,” including Taylor’s moans and comments about being “busted up” and “dying.” The appellate court wrote that a jailer does not have to know a detainee’s exact medical needs, thus a jury might find that a “reasonable lay person” who observed Taylor would see that medical treatment was required.
Finally, the Court of Appeals held that Alabama’s immunity shield law was not available to the defendants. As the jailers had “potentially violated Almus’ constitutional rights by being deliberately indifferent to his serious medical needs,” they were not entitled to immunity because the statute applies only when jailers “are acting in compliance with the law.”
Accordingly, the district court’s order of dismissal was reversed and the case remanded for further proceedings. In addition, district attorney Walt Merrell is opening an investigation into Taylor’s death. See: Taylor v. Hughes, 920 F.3d 729 (11th Cir. 2019).
Additional sources: nwfdailynews.com, dothaneagle.com, beasleyallen.com
Related legal case
Taylor v. Hughes
|Cite||920 F.3d 729 (11th Cir. 2019)|
|Level||Court of Appeals|
|Appeals Court Edition||F.3d|