×
You've used up your 3 free articles for this month. Subscribe today.
Eighth Circuit Revives § 1983 Complaint Alleging Jail Detainees’ Death from Stroke was Due to Deliberate Indifference and Failure to Train
Loaded on July 1, 2026
by Douglas Ankney
published in Prison Legal News
July, 2026, page 14
Filed under:
Systemic Medical Neglect,
Failure to Treat,
Eighth Amendment,
Failure to Train/Supervise,
Deliberate Indifference.
Location:
Minnesota.
by Douglas Ankney
The U.S. Court of Appeals for the Eighth Circuit revived a 42 U.S.C. § 1983 complaint (“Complaint”) that alleged claims of, inter alia, deliberate indifference to serious medical needs and a failure to train, on behalf of Jovon Mitchell who died from a stroke while …
Full article and associated cases available to subscribers.
As a digital subscriber to Prison Legal News, you can access full text and downloads for this and other premium content.
Already a subscriber? Login
More from this issue:
- He Died in a Florida Jail. The Company in Charge Should Have Sent Him to the Hospital, Experts Say., by Nichole Manna
- From the Editor, by Paul Wright
- $3.25 Million Verdict in New York Against Jail Medical Profiteer Armor Health, by Chuck Sharman
- Louisiana Republicans Eliminate Elected Office Won by Exonerated Ex-Prisoner
- After Spoliation Sanction, CoreCivic Settles Suit Over Suicide in New Mexico ICE Lockup, by Chuck Sharman
- California Appeals Court Sustains Amendments to CDCR that Narrow Youth Parole Eligibility Rules, by Douglas Ankney
- Detainee Deaths Went Unreported at Dallas County Jail
- Eighth Circuit Rules Plaintiff Must Cover Expert Costs, by Michael Thompson
- Wisconsin State Prison Population Approaches Record High
- Eighth Circuit Revives § 1983 Complaint Alleging Jail Detainees’ Death from Stroke was Due to Deliberate Indifference and Failure to Train, by Douglas Ankney
- Wisconsin Bans Recording of Prison Phone Calls with Journalists
- Conviction Tossed for Former Alabama Prisoner Paroled After 42 Years, by Chuck Sharman
- SCOTUS Continues to Hack Away At First Step Act, by Chuck Sharman
- California Supreme Court Limits Money Bail for Nonviolent Charges, by Chuck Sharman
- Idaho Supreme Court Holds Indigent Parents Have Constitutional Right to Counsel at Public Expense, by Matthew Clarke
- Alabama Barred from Executing Prisoner by Nitrogen Hypoxia, by Chuck Sharman
- North Texas Prison Evacuated After Carbon Monoxide Leak
- ICE Stops Reporting Deaths of Recently Released Detainees
- Oregon Supreme Court: Jail Credit Statute Focuses Upon Legal Custody Not Physical Custody Location, by David M. Reutter
- Missouri Bill Increases Mandatory Minimums, Expands Prosecutors’ Role in Juvenile Court, by Michael Thompson
- Free Phone Calls Saved Prisoners and Their Families More than $600 Million, Report Finds, by Matthew Clarke
- New York Governor Appoints Ex-Prisoner to State Oversight Role
- Ohio Jail Leaders Knew Cameras Were Broken for Four Years Before Fixing Them, by Jo Ellen Nott
- Fifth Circuit Kills Louisiana Prison Medical and Mental Health Care Reform, by Chuck Sharman
- SCOTUS Shuts Down GEO Group Bid for Immunity in Suit by Colorado ICE Detainees, by Chuck Sharman
- Rikers Island Captain Nicknamed “Terror of the Tombs” Indicted for Extortion, Wage Theft, by Jo Ellen Nott
- New Jersey Lawmakers Pass “Female Incarcerated Person’s Rights Protection Act”, by Douglas Ankney
- California Appeals Court Holds Defendant Cannot Be Penalized for Failing to Appear at Sentencing When He Was Being Held in Another County’s Jail on Preexisting Charges, by Matthew Clarke
- Idaho Will Recruit Law Enforcement Volunteers for Firing Squad Executions
- Louisiana’s Atavistic Approach to Criminal Sentencing and Parole Demonstrates Politicians’ Failure to Learn from Past Mistakes, by Douglas Ankney
- Corrections Board Seeks to Join California Justice Department Juvenile Halls Lawsuit, by Michael Thompson
- SCOTUS Reverses Mississippi Capital Conviction, by Matthew Clarke
- New York to Become First State to Require Judges to Visit Prisons
- Prisoners’ Risk of Death In Custody More than Doubles in Solitary Confinement, by Chuck Sharman
- $25,000 Paid to Former New York Jail Detainee Subjected to Delayed Healthcare and Denied Mental Healthcare— Despite Seven Suicide Attempts, by Chuck Sharman
- BOP Ordered to Restart Gender Affirming Care for Trans Prisoners, by Chuck Sharman
- BOP Supervisor in Colorado Indicted for Smuggling Over 400 Vapes
- Tenth Circuit Upholds $33 Million Jury Award in Suit Over Detainee’s Horrific Death in Oklahoma County Jail, by Matthew Clarke
- Multiple Detainees Escape from Dilapidated North Carolina Jail, by Jo Ellen Nott
- Colorado Ordered to Stop Tossing Prisoners in Solitary for Refusing to Work, by Chuck Sharman
- Arizona Lawmakers Refuse to Fully Fund Prison Healthcare Staffing Ordered by Federal Court, by Chuck Sharman
- Oklahoma Jail Closes After $2.55 Million Payout for Retaliatory Strip Search, by Chuck Sharman
- SCOTUS Refuses to Allow Damages Under RLUIPA for Rastafarian Former Prisoner Shaved Bald by Louisiana Prison Officials, by Chuck Sharman
- HRDC Wins Injunction to Halt New Mexico Prison Censorship, by Chuck Sharman
- Environmental Groups Say the Fight to Shut Down “Alligator Alcatraz” Isn’t Over, by Alexandra Martinez
- Tennessee Calls Off Execution After Botched Lethal Injection
- Video Shows Guards Watched as Oklahoma Detainee Died in Cell, by Michael Thompson
- $130,030 Jury Verdict for Connecticut Prisoner Subjected to Inhumane Conditions, by Chuck Sharman
- Three Women Died at a Michigan Prison in Less than a Month, by Jo Ellen Nott
- Eighth Circuit Revives Prisoner Lawsuit over Conditions of Confinement, by Michael Thompson
- Colorado Prison Wardens Participated in Longstanding Racist, Homophobic Group Chat
- Pennsylvania Bungles Management at George W. Hill Prison after Taking Back Control from GEO Group, by Michael Thompson
- Texas Prison System Bans Prisoners from Receiving Hardback and Used Books, by Matthew Clarke
- Execution Stayed for South Carolina Prisoner with Immortality Belief, by Michael Thompson
- Tainted Chicken Leads to Widespread Salmonella Outbreak at New York Jail
- Federal Conviction, Guilty Pleas for Jail Guards Responsible for Oklahoma Detainee’s Death
- California Gave Every Student in Prison a Laptop. How Community Colleges Are Using Them, by Ella Carter-Klauschie
- Colorado DOC Freezes Visitations After Two Prisoner Deaths
- San Diego Guard Who Fatally Shot Fleeing Detainee Sentenced to 12 Years in Prison, by Jo Ellen Nott
- News in Brief
More from Douglas Ankney:
- New Jersey Supreme Court Orders Plenary Hearing Before Special Adjudicator on Reliability of Fingerprint Evidence, Holding Century of Judicial Acceptance Did Not Satisfy Trial Court’s Gatekeeping Obligation Under N.J.R.E. 702, Aug. 1, 2026
- En Banc Eleventh Circuit Announces All Parents, Including Those Convicted of Child-Sex Offenses, Enjoy Fundamental Right to Live With Their Children, Holding Alabama Residency Prohibition Subject to Strict Scrutiny, Aug. 1, 2026
- Seventh Circuit Announces Courts May Examine Individual Officer’s Subjective Purpose When Assessing Whether Warrantless Administrative Inspection Was Pretextual, Holding Suppression Required Where Trooper’s Sole Motive for Stop Was Criminal Investigati, Aug. 1, 2026
- SCOTUS Holds § 922(g)(3) Prosecution Based Solely on Regular Marijuana Use, Without Individualized Proof of Dangerousness, Violates Second Amendment, Aug. 1, 2026
- Judge Grants Attorney’s Motion to Withdrawal from Corizon Health Case Due to Non-Payment, Aug. 1, 2026
- Abuse is No Excuse: Oklahoma’s Judges Deny Sentencing Relief to Prisoners Who Were Raped and Physically Assaulted, Aug. 1, 2026
- Audit of Louisiana DOC Finds Fault with Prisoner Release Calculation System, Aug. 1, 2026
- California Appeals Court Sustains Amendments to CDCR that Narrow Youth Parole Eligibility Rules, July 1, 2026
- Eighth Circuit Revives § 1983 Complaint Alleging Jail Detainees’ Death from Stroke was Due to Deliberate Indifference and Failure to Train, July 1, 2026
- California Court of Appeal Announces Defendants Who Exercise Right to Jury Trial on Aggravating Circumstances Are Entitled to Closing Argument by Counsel on Those Factors, July 1, 2026
More from these topics:
- $4.5 Million Paid by Cook County for Detainee Suicide in Chicago Jail, Aug. 1, 2026. Medical Neglect/Malpractice, Failure to Treat (Mental Illness), Suicides, Administrative Detention/Segregation, Deliberate Indifference.
- New York Ordered to Pay Prisoner $25,000 for Failing to Protect Him from Attack, Aug. 1, 2026. Failure to Protect (General), Defenses, Damages - Compensatory, Negligence/Reckless Endangerment, Deliberate Indifference.
- Oregon Agrees to $2.3 Million Settlement After Guards Toss Mentally Ill Prisoner in Solitary, Taunt Him Until He Kills Himself, Aug. 1, 2026. Control Units/SHU/Solitary Confinement, Failure to Treat (Mental Illness), Suicides, 42 U.S. Code § 1983, civil action for deprivation of rights, Deliberate Indifference.
- $10.19 Million Paid for Retired California Prison Guard’s Death in Colorado Jail, Aug. 1, 2026. Failure to Treat, Stun Guns/Tasers, Failure to Train/Supervise, Medical Neglect/Malpractice, Deliberate Indifference.
- Fourth Circuit Affirms Damages Class Certification in Opioid Treatment Denial, Aug. 1, 2026. Wexford Health Services, Drug/Alcohol Withdrawal, Failure to Treat, Class Certification, Deliberate Indifference.
- Ombudsman Report Finds Use of Force Misapplied in Contraband Search, Aug. 1, 2026. Guard Misconduct, Failure to Treat, Body Cavity Searches, Guard Brutality/Beatings, Pepper Spray/Tear Gas.
- $3.25 Million Paid by Georgia After Prisoner Bakes to Death in Outdoor Recreation Cage, Aug. 1, 2026. Failure to Treat, Exposure to Heat, Settlements, Medical Neglect/Malpractice, Deliberate Indifference.
- $100,000 Paid to New York Detainee Whose Infant Died in Syracuse Jail, Aug. 1, 2026. Naphcare, OB/GYN, Failure to Treat, Medical Neglect/Malpractice, Deliberate Indifference.
- Sixth Circuit Affirms Denial of State-Law Qualified Immunity in Scabies Case, Aug. 1, 2026. Corizon, Systemic Medical Neglect, Contagious Disease -- Misc., Qualified Immunity, Deliberate Indifference.
- Fourth Circuit Revives Disabled Prisoner’s Claim for Denial of Out-of-Cell Exercise Time, Aug. 1, 2026. Totality of Conditions, Eighth Amendment, Exercise, Summary Judgment, Qualified Immunity.

