February 22, 2021

The United States Court of Appeals for the Ninth Circuit (“Federal Appellate Court”) held in its opinion dated January 13, 2021: “Viewing the evidence in Plaintiff’s favor, a jury could conclude that Ronnie Sandoval would not have died but for the defendants’ unreasonable response to his obvious signs of medical distress. The district court therefore erred in granting summary judgment. We reverse and remand for further proceedings consistent with this opinion.”

The Underlying Facts

On February 22, 2014, deputies from the San Diego Sheriff’s Department went to Ronnie Sandoval’s residence to conduct a probation compliance check. After the deputies found a gram of methamphetamine and drug paraphernalia, they placed Sandoval under arrest and took him to the San Diego Central Jail. Unbeknownst to the arresting deputies, Sandoval had swallowed an additional amount of methamphetamine—later estimated to be several hundred times the typical recreational dose—in an effort to prevent its discovery.

Ronnie Sandoval died of a methamphetamine overdose at the San Diego Central Jail after medical staff left him unmonitored for eight hours, despite signs that he was under the influence of drugs, and then failed to promptly summon paramedics when they discovered him unresponsive and having a seizure. Sandoval’s wife and successor-in-interest, Ana Sandoval (“Plaintiff”), brought suit under 42 U.S.C. § 1983 against the County of San Diego and Nurses Romeo de Guzman, Dana Harris, and Maria Llamado, alleging that they violated Sandoval’s Fourteenth Amendment right to adequate medical care in custody.

Individuals in state custody have a constitutional right to adequate medical treatment. For inmates serving custodial sentences following a criminal conviction, that right is part of the Eighth Amendment’s guarantee against cruel and unusual punishment. However, pretrial detainees have not yet been convicted of a crime and therefore are not subject to punishment by the state. Accordingly, their rights arise under the Fourteenth Amendment’s Due Process Clause.

Claims brought by convicted prisoners under the Eighth Amendment are governed by a “subjective deliberate indifference” standard. Under this standard, a prison official will be liable for disregarding an inmate’s serious medical needs only if he was both aware of facts from which the inference could be drawn that a substantial risk of serious harm exists and actually drew the inference. Thus, a prison official who should have been aware of a medically related risk to an inmate, but in fact was not, has not violated the Eighth Amendment, no matter how severe the risk.

In 2015, the U.S. Supreme Court held that the Eighth Amendment and Fourteenth Amendment standards were not the same (“The language of the two Clauses differs, and the nature of the claims often differs.”). The Supreme Court concluded that for Fourteenth Amendment claims, the relevant question is not whether the defendant acted in good faith, but instead whether the force used was “objectively unreasonable.”

In 2016, the Federal Appellate Court held that Fourteenth Amendment failure-to-protect claims should be analyzed under an objective framework, under which the critical question is whether the defendant failed to take reasonable measures to abate a serious risk of harm to an inmate “even though a reasonable officer in the circumstances would have appreciated the high degree of risk involved—making the consequences of the defendant’s conduct obvious.”

In 2018, the Federal Appellate Court adopted an objective framework for claims brought by pretrial detainees alleging inadequate medical care that mirrored the framework for failure-to-protect claims. Under that standard, pretrial detainees alleging that jail officials failed to provide constitutionally adequate medical care must show: (1) The defendant made an intentional decision with respect to the conditions under which the plaintiff was confined [including a decision with respect to medical treatment]; (2) Those conditions put the plaintiff at substantial risk of suffering serious harm; (3) The defendant did not take reasonable available measures to abate that risk, even though a reasonable official in the circumstances would have appreciated the high degree of risk involved—making the consequences of the defendant’s conduct obvious; and (4) By not taking such measures, the defendant caused the plaintiff’s injuries. To satisfy the third element, the plaintiff must show that the defendant’s actions were “objectively unreasonable,” which requires a showing of “more than negligence but less than subjective intent—something akin to reckless disregard.”

The district court granted summary judgment to the defendants, concluding that there were no triable issues of fact as to their liability and that the individual nurses were entitled to qualified immunity. The Federal Appellate Court stated that in light of its holding in the 2018 case, “it is clear that the district court here erred by applying the subjective deliberate indifference standard to Plaintiff’s Fourteenth Amendment claim. Because the parties have briefed Gordon’s objective framework on appeal, we apply it here.” Applying that standard in the present case, the Federal Appellate Court reversed because genuine disputes of material fact preclude the award of summary judgment, and the Federal Appellate Court remanded for further proceedings.

Source Sandoval v. County of San Diego, No. 18-55289.

If you or a loved one were injured due to the lack of appropriate medical care while a pretrial detainee in the United States, you should promptly seek the legal advice of a local medical malpractice lawyer in your state who handles pretrial detainee medical malpractice claims and may investigate your claim and represent you or your loved one, if appropriate.

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