Fifth Circuit Denies Qualified Immunity to Mississippi Cops Who Let Injured Hemophiliac Bleed Out in Jail
by Matt Clarke
On July 15, 2022, the U.S. Court of Appeals for the Fifth Circuit affirmed the denial of qualified immunity (QI) to Mississippi jailers accused of ignoring the injuries and pleas for medical treatment of an injured hemophiliac detainee, who then bled to death internally.
When police in Yazoo City arrested Marshawn Williams for domestic violence in May 2014, the 24-year-old told responding Sgt. Arthur Thompson and Officers Kenyon Banks, Chris Dean, and Artis Harris that his girlfriend’s brother had hit him in the side with a metal pipe. He showed them the injury, which appeared to be superficial.
On the way to the police car, Williams struggled to walk and collapsed, his girlfriend, Lavina Smith, later recalled. Police, on the other hand, claimed he was passively resisting arrest. Nevertheless, he was loaded into the car and driven to the Yazoo County Jail.
Williams was in and out of consciousness while being booked. “At one point, he urinated on himself and slumped out of his chair to the ground,” the Court recalled. He was unresponsive to officers’ requests for personal information. But he was not screened for medical needs — even though he again required assistance walking to his cell.
Officer Patrick Jaco telephoned Smith to ask if Williams was sick or on any medication. Smith called Williams’ mother, who came to the jail to discuss her son’s medical condition. With Harris, Jaco, Dean, Banks, Officer Sharon VanCleave, and Jailer Tracey Langston present, she explained that Williams was not currently on medication, but “grabbed his side and fell over” before the arrest and his “blood does not clot normally so that ‘if he got hurt in any kind of way … he would just bleed.’” Williams’ sister chimed in, noting that “[H]e could die!”
Banks responded that Williams had passed out twice in front of them. But Dean dismissed these concerns, and officials did not take any action in response to this information.
From his cell, Williams repeatedly called out for medical care. After he lost consciousness, other detainees banged on their cell doors for two to three hours, attempting to get guards’ attention and secure medical aid.
It didn’t work. Williams was found dead in his cell around 2:00 a.m. on May 19, 2014. An autopsy revealed that he had died of massive internal bleeding due to a liver laceration.
Williams’ family filed suit in federal court for the Southern District of Mississippi. Proceeding under 42 U.S.C. § 1983, Plaintiffs accused the city, its police department and officers of deliberate indifference to his serious medical needs, in violation of his Eighth Amendment guarantee of protection from cruel and unusual punishment. Plaintiffs also lodged a claim for denial of medical care under federal and state tort laws.
Defendants filed for summary judgment, claiming QI. When the district court denied that claim as to the federal and state denial-of-care claims, Defendants filed an interlocutory appeal at the Fifth Circuit.
Taking up the case then, the Court said the city could not enjoy QI, pursuant to Owen v. City of Independence, 445 U.S. 622 (1980). Therefore, the Court lacked jurisdiction to hear the city’s appeal. Likewise, it lacked jurisdiction over the state denial-of-care claim.
As for the federal denial-of-care claim, the Court recognized that jails must provide for the safety and wellbeing of prisoners, as provided in DeShaney v. Winnebago Cnty. Dep’t of Soc. Servs., 489 U.S. 189 (1989). “The Fourteenth Amendment thus bars law enforcement from responding to a detainee’s serious medical needs with deliberate indifference,” the Court continued, citing Farmer v. Brennan, 511 U.S. 825 (1994). Taking Plaintiffs’ allegations as true, which it must at the pleading stage, the Court said: “[T]his is not a close case.”
Defendants knew Williams was a hemophiliac. They knew he was injured. And they knew he was requesting medical care. That means “they knew of the risk to his life and were obligated to take reasonable action to abate that risk,” the Court continued. Yet they did nothing.
Citing Nerren v. Livingston Police Department, 86 F.3d 469 (5th Cir. 1996), the Court said it had been clearly established for at least 26 years that an official who ignores a pretrial detainee’s serious medical needs violates that detainee’s rights. Therefore, the district court’s denial of QI to the individual defendants was affirmed on the federal denial-of-care claim. See: Williams v. City of Yazoo, 41 F.4th 416 (5th Cir. 2022).
The case has now returned to the district court, and PLN will report developments as they are available. Williams’ family is represented by attorneys Richard P. Williams and Daryl M. Newman of Williams Newman Williams, P.L.L.C., in Jackson, along with Vallrie L. Dorsey of Dorsey & Gates, P.L.L.C., in Greenwood. See: Williams v. City of Yazoo, USDC (S.D. Miss.), Case No. 3:15-cv-00103.
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