Thursday, December 15, 2022
Officers Who Rely on Judgment of Jail Medical Unit Get Qualified Immunity, Seventh Circuit Says
The Seventh Circuit ruled that corrections officers who were tasked with transferring a pretrial detainee out of a county jail's medical unit enjoyed qualified immunity from the detainee's estate's civil rights suit for his death, because they relied on the judgment of jailhouse medical staff.
The ruling ends this part of the estate's lawsuit against the officers.
The case, McGee v. Parsano, arose when a diabetic detainee exhibited symptoms commonly associated with diabetic ketoacidosis, but was refused medical treatment because a jailhouse nurse thought he was faking. The detainee then died.
The detainee's estate sued officers who were tasked with transferring the detainee out of the medical unit just before his death. (The estate sued the medical staff, too, but that's not at issue in this case.)
The Seventh Circuit ruled that the officers enjoyed qualified immunity from the suit, because they relied on the judgment of medical staff in declining to provide treatment.
[C]orrections officers are not constitutionally obligated to override the judgment of medical professionals unless they have reason to know that an inmate is receiving inadequate treatment. This remains true even when an inmate is in obvious distress and even when the medical staff has misdiagnosed an inmate--or worse, accused him of faking a very real illness. * * * [A] corrections officer may trust jail medical professionals to provide inmates with appropriate medical care. There is accordingly no legal basis for McGee's contention that at the time of Carter's death, the law was clearly established in her favor.