Background Facts
The jail took custody of Donnie Locklear, Jr. around 2:13 a.m. on May 17, 2020—almost twenty minutes after his arrival. During the booking process, Locklear struggled to articulate his medical history and conditions but did report he took blood pressure medication. He did not know the name of the drug. After Locklear disclosed thoughts of self-harm, the shift supervisor placed him on suicide watch, requiring jailers to check on him every fifteen minutes and record their
observations. Those supervision logs note he was “shaking” and “anxious” at times during his jail stay.
An onsite nurse and physician’s assistant at another location were looped in, and they offered various interventions, including requesting records from Locklear’s medical care providers. In addition, a correctional officer checked
Locklear’s vital signs. On May 18, when Locklear complained of chest pain, Corporal Witt performed the jail’s chest pain protocol. Again, the physician’s assistant and the nurse offered advice and care. Throughout this time, a care log was kept which described Locklear’s condition, the interventions, and some notes that on two occasions his shaking started after becoming aware of approaching staff.
The next morning, May 19, Locklear again complained of chest pain. The jail received his medical records from UnityPoint. After giving Locklear low-dose aspirin, they called paramedics to the jail. They took him to the UnityPoint emergency department, after which an ambulance transferred him to the University of Iowa Hospitals and Clinics. Later, Locklear was diagnosed with a renal infarction involving large portions of his right kidney and renal artery stenosis.
Locklear sued the county and brought six claims: (1) deprivation of due process in violation of article 1, section 9 of the Iowa Constitution, (2) unreasonable detention or denial of medical care in violation of article 1, section 17 of the Iowa Constitution, (3) negligence, (4) reckless disregard for his care and safety, (5) deliberately indifferent policies, practices, customs, training, and supervision, and (6) violation of Iowa Code chapter 22 open records laws.
The district court dismissed counts (1), (2), and (5), leaving his claims of negligence, reckless disregard, and an open records violation to proceed. The county moved for summary judgment on those three claims. Locklear resisted and cross-moved for partial summary judgment. He argued there were genuine issues of material fact for his negligence and reckless-disregard allegations and that he was entitled to summary judgment on his open records claim. The district court granted the county’s motion for summary judgment on all three claims. Locklear appealed.
The Court of Appeals of Iowa stated in its April 15, 2026 Opinion: “[W]e agree with Locklear that in alleging jail personnel were negligent—or even reckless—by failing to provide prompt medical attention after seeing his suffering and symptoms, he was raising a claim of deficient custodial care, not medical negligence by health professionals.”
“Viewing the record in the light most favorable to Locklear, we find he is alleging ordinary negligence—not requiring a medical expert—in the period between his arrival at the sally port and his first access to medical aid when he was seen by a nurse ten hours later. Contrary to the district court’s findings, Locklear is not contesting the performance of the jail’s medical staff in treating his condition. Rather, he alleges that the jail staff denied him timely access to medical care. Courts have recognized “a distinction between claims based on negligent ‘diagnosis, treatment or care,’ as contemplated by the medical malpractice statute, and allegations concerning the proper performance of the sheriff’s custodial obligations to an inmate.” … As Locklear contends, the county had a common-law duty to provide him with the necessary attention for any serious medical needs known to jail staff.”
“Locklear’s claim is that he suffered “excruciating pain” waiting for medical treatment, not that the delayed treatment caused or worsened his renal infarction or renal artery stenosis. We agree with Locklear that it is within the knowledge of an ordinary layperson to determine whether someone is suffering as they wait to be treated. No medical expert is required to show causation.”
Source Estate of Donnie Locklear Jr. v. Muscatine County, No. 24-1768.
If you or a loved one were injured due to deliberate indifference or the lack of appropriate medical care while incarcerated in a prison, jail, or other correctional facility in the United States, you should promptly seek the legal advice of a local medical malpractice lawyer in your state who handles prisoner/inmate medical malpractice claims and may investigate your claim and represent you or your loved one, if appropriate.
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