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Eleventh Circuit Holds Estate Cannot Sue Jailers Who Followed Medical Personnel Advice That Led to Detainee’s Death
Loaded on Feb. 1, 2026
by Matthew Clarke
published in Prison Legal News
February, 2026, page 31
Filed under:
Drug/Alcohol Withdrawal,
Private Contractors,
Failure to Treat,
Medical Neglect/Malpractice,
Deliberate Indifference.
Location:
Georgia.
by Matt Clarke
On December 1, 2025, the United States Court of Appeals for the Eleventh Circuit held that jailers could not be held liable for the death of a Georgia pretrial detainee caused by lack of medical care. The Court’s rationale was that the jailers followed the …
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More from this issue:
- Most U.S. Prisoners Now Barred from Directly Receiving Physical Mail, by Chuck Sharman
- From the Editor, by Paul Wright
- Barbaric and Deadly Conditions Continue to Plague Los Angeles County Jails, by Douglas Ankney
- New Hampshire Prison System Struggles to Hire Guards
- Washington County Pays $300,000 to Jail Detainee Denied Treatment for Kidney Stone, by Chuck Sharman
- Michigan Claws Back $1.2 Million Paid to Wrongfully Convicted Former Prisoner, by Chuck Sharman
- Dissenter Excoriates SCOTUS for Denying Certiorari in Challenge to Constitutionality of Nitrogen Hypoxia Execution, by Matthew Clarke
- Report: Incarcerated Population in Rural Jails and Prisons At Risk of Losing Hospital Access, by Michael Thompson
- Three Prisoners Killed in Fight at Georgia Prison
- $450,000 Paid for Michigan Jail Detainee’s Fentanyl Death, Incarcerated Husband Prevails in Claim for Part of Payout, by Chuck Sharman
- North Carolina Parole Commission Agrees to Stop “Moving Goalposts” for Prisoners Who Committed Crime as Juveniles, by Chuck Sharman
- Escape from Georgia Jail Ends in Florida after Lyft Hijacking, by Jo Ellen Nott
- FCC Releases Final Version of Order Gutting 2024 Phone Cap Regulations, by Michael Thompson
- Half of South Dakota’s Prison Population Returns to Prison
- D.C. Federal Court Holds Blocking Prison Reform Advocate’s Access to Federal Prisoners May Violate First Amendment and Due Process, by Matthew Clarke
- $2 Million Settlement Reached for 12-Year-Old’s Gang Rape in Detroit Juvenile Detention Center, by Chuck Sharman
- The St. Louis Jails Are Running Out of Guards, by Ivy Scott
- Virginia Prisoners Stuck Waiting for Education Programs, by Anthony Accurso
- Killings Inside Mississippi’s Prisons Continue Unabated But Report Prompts DOC to Reopen Investigations, by Douglas Ankney
- California Appeals Court Rules in Favor of Ripped Off Prisoner, by Michael Thompson
- Alaska Deaths in Custody Tie Record High
- Los Angeles County Restricts Opioid Treatment, by Michael Thompson
- Federal Death Row Prisoners Granted Clemency by Biden Are Facing Retaliation by Trump, by Michael Thompson
- Eleventh Circuit Holds Estate Cannot Sue Jailers Who Followed Medical Personnel Advice That Led to Detainee’s Death, by Matthew Clarke
- Cuyahoga County Receives Over $846,000 Refund from Securus Technologies
- HRDC Sues Minnesota DOC Over Censorship Policy, by Robert Haughn
- Sixth Circuit Reinstates Lawsuit Over Failure to Properly Classify Violent Prisoners at Kentucky Jail, by Matthew Clarke
- Competency Crisis in Missouri’s Jails, by Douglas Ankney
- Alabama and Wexford Health Pay Undisclosed Settlement for Delays Costing Prisoner Partial Foot Amputation, by Chuck Sharman
- Eleventh Circuit Holds Alabama County May Be Liable for Policy of Providing Inadequate Jail Medical Care, by Matthew Clarke
- Punished for Bleeding: How Periods in Prison Become a Trap, by Candace Norwood
- Tenth Circuit Reverses Summary Dismissal of Claim Over Prisoner’s Suicide in Oklahoma Jail, by Matthew Clarke
- Ninth Circuit: Notice of Appeal of Order Denying Qualified Immunity Must Be Filed Within 30 Days of Entry, by Douglas Ankney
- Two Mississippi Prisons Lose Power During Winter Storm
- Deportation of Kenyan Priest Working as Texas Prison Guard Highlights TDCJ’s Dependence on Immigrant Staff, by Matthew Clarke
- Delaware Settles Suit Over Depriving Young Prisoners of Special Education, by Chuck Sharman
- Differing Judicial Outcomes for the New York Guards Who Killed Robert Brooks, by Jo Ellen Nott
- New York State Prisons Turning Away Visitors with Tampons After Scan
- Georgia Grand Jury Dings Augusta Jail for Overcrowding Days Before Violent Detainee Assault, by Chuck Sharman
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- County Jail in Oklahoma Accused of Coercing Detainees to Convert to Christianity
- Federal Court Strikes Much of Virginia’s Felony Voting Restriction, by Chuck Sharman
- Arkansas Bans Outside Reading Material Sent to Prisons, by Jo Ellen Nott
- The New York Prison System’s Culture of Cruelty and Impunity, by Michael Thompson
- Report on Baltimore Jail Reveals Human Waste Dripped from Ceilings
- Pennsylvania County Renews $8 Million Contract with PrimeCare Despite Settlements
- “Critical Labor Shortage” Declared at Two Rural Prisons in Nevada
- Idaho Prisons Are Full. Costs for Incarcerating Inmates in Jails and Out of State Are Skyrocketing, by Laura Guido
- California Oversight Agency Hasn’t Finished a Single Review of Jail Deaths
- Missouri Prisoners Forced to Shovel Snow in Subzero Temperatures
- New York State Moves to Dismiss Hundreds of Prison Sexual Assault Lawsuits, by Jo Ellen Nott
- United States Postal Service Declares Postmarks Could Be Delayed
- News in Brief
More from Matthew Clarke:
- Eleventh Circuit Reinstates Alabama Prisoner’s Excessive Prison Violence Claim, Oct. 1, 2026
- Eleventh Circuit Upholds Most of Relief Ordered in Class-Action Lawsuit Challenging Unconstitutionally Inadequate Mental Health Care in Alabama Prisons, Oct. 1, 2026
- Fourth Circuit Upholds Denial of Qualified Immunity to Jail Supervisors Who Ignored Detainee’s Cranial Abscesses, Oct. 1, 2026
- Eighth Circuit Reverses District Court’s Denial of Motion to Dismiss Some Defendants from Lawsuit Over Missouri Prisoner’s Suicide, Oct. 1, 2026
- Eighth Circuit Grants Summary Judgment to Sheriff and County of Nebraska Jail Where Guard Sexually Assaulted Female Prisoner, Oct. 1, 2026
- Federal Court Orders Texas to Admit Incompetent Jailed Defendants to Mental Health Facilities Within 21 Days, Oct. 1, 2026
- Seventh Circuit Grants Qualified Immunity to Detectives Who Revealed Prisoner Was Informant, Denies Him Anonymity, Aug. 1, 2026
- Seventh Circuit Holds Federal Law Prohibits County Jail from Forcing Immigration Detainees to Perform Custodial Labor by Threatening Solitary Confinement, Aug. 1, 2026
- New Mexico Supreme Court Holds Corrections Department Regulations Do Not Exempt Use-Of-Force Documents from Public Records Disclosure, Aug. 1, 2026
- DOJ Issues Memorandum Over BOP Employees Abusing Their Law Enforcement Credentials to Illegally Purchase Personal Firearms, Aug. 1, 2026
More from these topics:
- Class Action Certified in Lawsuit Alleging Raw Sewage Presence in Washington Jail, Oct. 1, 2026. Plumbing, Sewage, Sanitation, Class Certification, Deliberate Indifference.
- $700,000 Paid by West Virginia for Jail Death, Claims Against Wexford Health Pending, Oct. 1, 2026. Wexford Health Services, Restraints, Settlements, Excessive Force (Wrongful Death), Deliberate Indifference.
- BOP Prisoner’s Claim Over Denied Medical Care Ruled Impermissible Bivens Extension, Oct. 1, 2026. OB/GYN, Failure to Treat, Administrative Exhaustion (PLRA), Grievances, Adequacy of Remedy.
- Fourth Circuit Upholds Denial of Qualified Immunity to Jail Supervisors Who Ignored Detainee’s Cranial Abscesses, Oct. 1, 2026. Failure to Treat, Infections, Qualified Immunity, Fourteenth Amendment, rights, Deliberate Indifference.
- Federal Jury Returns $763,000 Verdict Against Centurion for Indiana Prisoner’s Denied Kidney Disease Treatment, Oct. 1, 2026. Centurion, Medication, Pain, Failure to Treat, Deliberate Indifference.
- Sixth Circuit: Qualified Immunity Granted to Guard in Delayed Treatment for Prisoner who Suffered Heart Attack, Oct. 1, 2026. Pain, Cardiovascular, Failure to Treat, Qualified Immunity, Deliberate Indifference.
- Last of Three Oklahoma Jail Death Settlements Totaling $66.5 Million Paid for Fatal Dehydration of “Cookie Queen”, Oct. 1, 2026. Diabetes, Settlements, Medical Neglect/Malpractice, Failure to Treat (Mental Illness), Deliberate Indifference.
- Tenth Circuit Vacates Award of Costs to Prison Officials, Revives Prisoner’s Claim Alleging Denial of Access to Functioning Toilets and Exposure to Other Prisoners’ Feces, Oct. 1, 2026. Plumbing, Sanitation, Summary Judgment, Costs, Deliberate Indifference.
- Eighth Circuit Reverses District Court’s Denial of Motion to Dismiss Some Defendants from Lawsuit Over Missouri Prisoner’s Suicide, Oct. 1, 2026. Qualified Immunity, Sovereign Immunity, Failure to Protect (Wrongful Death), Suicides, Deliberate Indifference.
- Disabled Prisoners in New York Aren’t Receiving Entitled Accommodations, Oct. 1, 2026. Disabled Prisoners, Retaliation for Filing Grievances, Failure to Treat, Americans with Disabilities Act.

