This case is a claim by the estate of a pre-trial detainee who was denied adequate medical care by jail nurses while he was held in detention. Although he was known to be withdrawing from heroin, the jail nurses put him in a restraint chair and failed to properly treat his serious medical needs. He died a few days later in the hospital from a stroke caused by endocarditis, a not-uncommon condition among intravenous drug users. The district court dismissed the claim against the nurses because it was not proved that they knew of the detainee’s serious medical need. In doing so, the court rejected the standard proposed by the estate: that nurses should have known that the detainee needed medical care.
The standard for deliberate indifference to serious medical needs has traditionally been a 2-prong test: (1) objective proof that a serious medical need wasn’t met and (2) proof the actor knew, subjectively, of the need but disregarded it. This 2-prong framework had been used to resolve claims of deliberate indifference raised by prisoners under the 8th amendment as well as to resolve claims by pre-trial detainees under the Due Process clause.
Our amicus brief was filed on August 27, 2021. Appellees opposed the filing of our brief on September 16, and we replied on September 23. Appellee’s brief was filed on September 30.