This summary also appears under Constitutional Law
Issues: "Deliberate indifference" to a prisoner's medical needs; 42 USC § 1983; U.S. Const. amend. VIII; U.S. Const. amend. XIV; Estelle v. Gamble; Farmer v. Brennan; Comstock v. McCrary; Whether the plaintiff established the subjective component of a deliberate indifference claim for each defendant; Gray v. City of Detroit; Jones v. Muskegon Cnty.; LeMarbe v. Wisneski; Westlake v. Lucas; Phillips v. Roane Cnty., TN; Johnson v. Karnes; Williams v. Mehra; Failure to train; Street v. Corrections Corp. of Am.; Miller v. Sanilac Cnty.; State-law claims; Moon v. Harrison Piping Supply; United Mine Workers of Am. v. Gibbs; Registered Medical Assistant (RMA); Licensed Practical Nurse (LPN)
Court: U.S. Court of Appeals Sixth Circuit
Case Name: Rouster v. County of Saginaw
e-Journal Number: 56841
Judge(s): Moore, Cook, and Gwin
[This appeal was from the ED-MI.] The deceased prisoner's estate may not sue Saginaw County's medical staff for "medical indifference" under § 1983 after they treated him for alcohol withdrawal but he died from a perforated duodenal ulcer. Even though the treatment fell below the standard of care, there was insufficient evidence that they were aware of his serious medical condition and "deliberately refused to provide appropriate treatment." The court concluded that it was clear the decedent "had an objectively serious need for medical treatment." The central issue on appeal was whether plaintiff provided sufficient evidence to prove the subjective component of the deliberate indifference inquiry. The decedent was originally diagnosed with alcohol withdrawal. Defendant-Conley, the RMA, "assessed [his] symptoms (e.g., cramping and diarrhea) and misdiagnosed him as suffering from gas and diarrhea." She then provided him with over-the-counter medication. Had she "been subjectively aware of the seriousness of [his] medical condition, her decision to treat him only with over-the-counter medication might have been so cursory as to amount to a conscious disregard of his needs." But the plaintiff failed to establish that Conley had a "very critical piece of information"- knowledge of the decedent's previous treatment for a perforated duodenal ulcer. The plaintiff also did not establish that defendant-Marrs, a LPN, "was subjectively aware" of the decedent's "serious medical needs and was deliberately indifferent to his welfare." She also treated him for alcohol withdrawal and was unaware of his medical history. Moreover, most of his "symptoms were entirely consistent with those experienced by patients suffering from alcohol withdrawal." The plaintiff also failed to show that defendant-Menchaca, a LPN, was indifferent to the decedent's medical needs. She "believed that [he] was suffering from alcohol withdrawal, and she treated him appropriately for the medical needs that she believed he had." The medical care the staff provided "was questionable. Medical staff providing proper care would have, in an abundance of caution, caused [the decedent] to see a physician when he began experiencing severe abdominal pain; at the least, they would have continued to assess his abdomen for rigidity or other signs of 'acute abdomen' while he was held in observation." However, this did not constitute "deliberate indifference." Had they been aware of his medical history, the court could have "easily" concluded that they were "deliberately indifferent" to his needs. But Conley, Menchaca, and Marrs were entitled to summary judgment. Because the plaintiff failed to establish a constitutional violation, the district court properly granted defendant-Secure Care summary judgment on the failure-to-train claim. The district court also properly declined to exercise supplemental jurisdiction over the state-law claims. Affirmed.
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