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Webb v. Jessamine County Fiscal Court
Citations: 802 F. Supp. 2d 870; 2011 U.S. Dist. LEXIS 87105; 2011 WL 3439128Docket: Civil Action No. 5:09-CV-314-JMH
Court: District Court, E.D. Kentucky; August 5, 2011; Federal District Court
In the case of Ashley Mae Webb v. Jessamine County Fiscal Court, the plaintiff alleges that the defendants, including Jessamine County officials and detention center staff, were deliberately indifferent to her serious medical needs, resulting in her giving birth unassisted in a detention cell, which she claims violated her Eighth Amendment rights against cruel and unusual punishment. Webb's amended complaint includes accusations of negligence and intentional infliction of emotional distress under Kentucky common law. On August 25, 2006, Webb, who was nine months pregnant, was booked into the Jessamine County Detention Center (JCDC). She reported severe back pain and other labor-related symptoms to Deputy Jailer Tami Jean Teaven, who only provided minimal relief, such as an aspirin substitute. Despite Webb's continuous complaints, including the breaking of her water, Teaven failed to summon medical assistance. After several hours of labor, EMS was only contacted when it was evident that Webb's situation was critical. Jailer Cecil Ray Moss was not present at the time, and although Lt. James David Crowe was aware of Webb's pregnancy and monitored the situation, he did not intervene effectively. The court's decision on the defendants' motion for summary judgment is noted to be partially granted and partially denied, although the specific outcomes of the claims are not detailed in the excerpt. Watts was aware of the Plaintiff's pregnancy and had some knowledge of the complaints that led to Teaven transferring Webb during her labor, relying on reports from Crowe and Teaven. Ultimately, Watts conveyed Teaven's request for Emergency Medical Services (EMS) to another guard. Although the Plaintiff delivered a healthy baby without physical injuries, she experienced embarrassment and humiliation during the process. The standard for summary judgment aligns with that for a directed verdict, requiring that no genuine issue of material fact exists, allowing the moving party to prevail as a matter of law. The initial burden rests on the moving party to demonstrate the absence of genuine material facts, which can be satisfied by showing a lack of evidence on a crucial fact the nonmoving party must prove at trial. If the moving party meets this burden, the nonmoving party must present probative evidence supporting their claims. A material fact is defined as one that could influence the trial's outcome, and a genuine dispute exists if a reasonable jury could potentially rule in favor of the nonmoving party. The judge's role is to determine if genuine issues remain for trial, without weighing the evidence, and all evidence must be viewed in the light most favorable to the nonmoving party. Regarding the claims under 42 U.S.C. § 1983, Defendants Crowe, Watts, and Moss are entitled to qualified immunity in their individual capacities, while Teaven is not. The court must assess whether the Defendants' actions violated clearly established rights that a reasonable person would recognize. If the Defendants claim qualified immunity, the burden shifts to the Plaintiff to demonstrate that the Defendants are not entitled to such immunity. To prevent summary judgment based on qualified immunity, the Plaintiff must show both a violation of a constitutional right and that this right was clearly established at the time of the alleged misconduct. The Plaintiff's claims center on her Eighth Amendment right to be free from cruel and unusual punishment. Plaintiff alleges that individual defendants violated the Eighth Amendment by delaying medical care during her labor, claiming this constituted cruel and unusual punishment. To establish an Eighth Amendment claim regarding medical care, a plaintiff must demonstrate 'deliberate indifference' through a two-pronged test: an objective component showing a "sufficiently serious" medical need and a subjective component indicating that the prison official possessed a "sufficiently culpable state of mind." The court considers whether the plaintiff had an objectively serious medical need. It is noted that pregnancy alone does not qualify as such, but complications can arise that necessitate immediate attention. There is consensus that an inmate in labor has a serious medical need, which both parties acknowledge. The court agrees that labor requires immediate medical attention by contemporary standards, as it is expected that a woman in labor receives monitoring and care regardless of the setting. Defendants contest that the plaintiff has not provided "verifying medical evidence" proving she was in labor before her water broke, arguing that this undermines her claim of an objectively serious medical need that would obligate them to seek medical care prior to that event. Defendants' argument regarding the 'verifying medical evidence' requirement is inadequately applied, as it pertains only to claims involving minor ailments or less obvious medical needs. In cases where there is an evident need for medical attention, such as labor, courts do not require such verification. Defendants assert that serious medical needs are only apparent when a woman's amniotic sac ruptures, but this is an oversimplification. Courts must conduct a detailed analysis, considering the time remaining in the pregnancy, labor symptoms, any prior complications, and the response of jail officials. The court distinguishes this case from Patterson v. Carroll County Detention Center, noting that the plaintiff in Patterson was in her second trimester and showed no significant complications before labor. In contrast, the current plaintiff, Webb, was at or near full term, demonstrating clear signs of labor shortly after booking. The court finds that a reasonable jury could determine Webb had a serious medical need during the night she exhibited symptoms consistent with labor, including sharp pain, cramping, and significant pressure. Webb's condition was compounded by her advanced pregnancy and the physical signs she presented, culminating in the birth of her child, which ultimately confirmed her labor status. Plaintiff has successfully demonstrated that a layperson would recognize her labor as a serious medical condition, satisfying the objective requirement for showing deliberate indifference under the Eighth Amendment. Viewing the evidence favorably for Plaintiff, a reasonable jury could find her condition constituted a serious medical issue, indicating a potential violation of her right to medical care. While Plaintiff did not establish the necessary state of mind for defendants Crowe, Watts, or Moss, a genuine issue of fact remains regarding Teaven's state of mind. The subjective element of the deliberate indifference test assesses whether a defendant knowingly disregarded a substantial risk to the prisoner’s health. Plaintiff is not required to provide direct evidence of intent to inflict pain but must show that the official recognized a risk and chose to ignore it. Circumstantial evidence can imply that prison officials were aware of serious risks, particularly if the risks were apparent. The Court finds sufficient grounds for a jury to conclude that Teaven recognized the signs of Plaintiff's labor and disregarded her condition. Teaven was aware of Plaintiff's advanced pregnancy and witnessed multiple signs of labor, yet delayed calling for assistance despite being informed of the rupture of Plaintiff's amniotic sac. Teaven’s dismissal of Plaintiff's symptoms as not serious further supports the inference that she disregarded the obvious risk to Plaintiff's health. Thus, the evidence suggests Teaven could be liable for deliberate indifference to Plaintiff’s medical needs. Summary judgment on qualified immunity for Teaven is denied due to the established right against cruel and unusual punishment arising from deliberate indifference to an inmate's serious medical needs, which was clearly established at the time of the alleged misconduct. Teaven did not dispute this established right, which is supported by case law. In contrast, Crowe, Watts, and Moss did not have sufficient involvement or knowledge of the situation to warrant liability. Crowe was aware that Webb was pregnant and heard commotion but lacked direct knowledge of her medical condition due to incomplete records of communication from Teaven. Watts had limited awareness based on reports from others and did not directly observe Webb, while Moss had no evidence of being present or informed of Webb's condition. Consequently, the Court granted summary judgment in favor of Crowe, Watts, and Moss, affirming their entitlement to qualified immunity regarding the deliberate indifference claim. Additionally, the plaintiff alleged a violation of her rights due to inadequate hiring, training, supervising, and disciplining of jail employees. The Court must evaluate whether these claims constitute a constitutional violation and whether the right was clearly established to assess the applicability of qualified immunity. Plaintiff's claim regarding constitutional rights violations stemming from the jail's hiring practices is insufficiently supported. The core of her argument is that Jailer Moss hired Teaven without verifying her certification as a certified nursing assistant (CNA). To establish a negligent hiring claim, Plaintiff must demonstrate that Teaven's background clearly indicated that hiring her would result in a constitutional rights violation. However, Plaintiff has not provided evidence showing that Moss should have recognized a serious risk associated with Teaven's employment. Regarding the failure to train claim, the Sixth Circuit mandates that a plaintiff identifies specific actions of individual supervisors to counter a qualified immunity defense. Plaintiff has failed to do this, lacking a clear account of supervisory dynamics on the relevant night, leading to an absence of genuine factual disputes concerning her claims against the defendants in their individual capacities. Moreover, under Section 1983, liability does not arise merely from a supervisor's failure to oversee employees unless the supervisor directly participated in or condoned the misconduct. Plaintiff contends that Jailer Moss implicitly approved of Teaven's actions, particularly regarding her authority to determine when to summon emergency medical assistance for an inmate, which allegedly contradicted state law and jail policies. The court, however, is not convinced that this authorization violated the jail's procedures, which stipulated that officers should contact medical personnel in emergencies in accordance with established protocols. Moss's admission that a Certified Nursing Assistant (CNA) cannot diagnose medical conditions does not substantiate Webb's claim of harm due to a failure to supervise. Webb has failed to demonstrate how assigning evaluative tasks to a CNA resulted in constitutional violations. Furthermore, under Section 1983, the relevant issue is whether the defendants violated constitutional rights, not whether there was a failure to discipline employees. Citing precedent, the court notes that failure to discipline does not alone constitute a constitutional violation unless it reflects a policy or custom that ratifies unlawful acts. Webb has not articulated how the jail's investigatory and disciplinary practices violated her rights, leading to the conclusion that her claims fail. Consequently, because Webb did not identify any significant constitutional violations regarding hiring, training, supervision, or discipline, the defendants are entitled to qualified immunity, and the court grants their Motion for Summary Judgment on all remaining allegations under Section 1983. Regarding claims against the Jessamine County Fiscal Court and JCDC in their official capacities, these are treated as claims against the office itself. To establish liability, it must be proven that the alleged harm resulted from a constitutional violation and that the municipality is responsible for that violation. Local governments cannot be held liable under Section 1983 for injuries caused solely by their employees, as liability cannot be based on respondeat superior. Instead, liability arises when a governmental policy or custom inflicts injury. The plaintiff must identify the specific policy, connect it to the municipality, and demonstrate that her injury was a result of that policy. Additionally, a widespread practice that is long-standing and customary can also establish liability, even in the absence of formal written policies. Plaintiff's claims against the Jessamine County Fiscal Court and individual defendants in their official capacities are dismissed due to a failure to identify a policy or custom that caused her injury under 42 U.S.C. § 1983. The Plaintiff did not present evidence of a written law, express municipal policy, or widespread practice at the Jessamine County Detention Center (JCDC) that would implicate the county in her claims. Although she referenced the JCDC policy manual regarding medical emergencies, she did not demonstrate how it directly caused her harm, instead suggesting a failure to follow that policy led to her injury. The argument regarding Jailer Moss's practice of allowing a CNA officer to decide when to call for medical help was not sufficient to establish a widespread custom causing her injury, as it did not imply a delay in seeking aid for inmates. The evidence presented reflects isolated actions by jail employees rather than a persistent, systemic issue attributable to the Fiscal Court, thus failing to meet the standard for municipal liability established in relevant case law. Additionally, the claims for negligence and intentional infliction of emotional distress are barred by sovereign immunity under Kentucky law, as Jessamine County, being a political subdivision, is protected from lawsuits unless immunity is explicitly waived by the General Assembly. Since the JCDC is operated under the authority of the county, the immunity extends to it as well. Consequently, the Court grants Defendants' Motion for Summary Judgment regarding both federal and state claims. Absolute immunity from suit applies to Jessamine County and its officials when they are sued in their official capacities regarding actions connected to the county's operations. This immunity persists when the claims are related to the wrongful operation of the jail, as the state is the real party in interest. The Plaintiff contends that KRS 71.040, which outlines the jailer's duties regarding the care and humane treatment of inmates, constitutes a waiver of this immunity. However, the court interprets the statute strictly in favor of the state and finds no clear legislative intent to waive immunity. Consequently, the court concludes that both the county and the individual defendants are entitled to immunity from the Plaintiff's state law claims of negligence and intentional infliction of emotional distress. Furthermore, claims against the individual defendants for negligence and intentional infliction of emotional distress are rejected due to the Plaintiff's failure to demonstrate an injury resulting from their actions. Under Kentucky law, establishing negligence requires proof of duty, breach, and injury. The court notes that jailers are mandated to provide humane treatment and necessary medical care, as stipulated in KRS 71.040, and that regulations ensure inmates receive emergency medical care comparable to community standards. Nevertheless, based on the evidence presented, the court finds no genuine issue of material fact regarding the individual defendants’ liability, leading to the dismissal of these claims. A person injured by a statute violation may recover damages due to that violation. In this case, a genuine issue of material fact pertains only to Teaven's actions concerning the Plaintiff's negligence claim. Teaven was aware that Webb required assistance but did not take action to provide necessary care, leaving the Plaintiff to labor for hours unattended in a jail cell. The Plaintiff experienced significant discomfort, pain, embarrassment, and humiliation during childbirth due to the lack of care. Despite Teaven's negligence, neither the Plaintiff nor her child suffered physical harm. The ruling indicates that Teaven had the knowledge that created a duty to act, while no evidence suggested that Defendants Moss, Crowe, or Watts had similar knowledge, leading to the dismissal of the negligence claim against them in their individual capacities. Additionally, the Plaintiff failed to provide evidence that the Defendants intended to cause emotional distress, which is required under Kentucky law. Although Teaven's actions may have been neglectful and disrespectful, they did not meet the threshold for intentional infliction of emotional distress. As a result, the Court granted in part and denied in part the Defendants' Motion for Summary Judgment. The Plaintiff's claims under 42 U.S.C. § 1983 and her claims of intentional infliction of emotional distress and negligence against all Defendants were dismissed with prejudice. Yanero v. Davis, 65 S.W.3d 510 (Ky. 2001) applies to the analysis of qualified immunity in the context of state claims under Kentucky law, but does not extend to federal qualified immunity. In Williams v. Simpson, the application of Kentucky's qualified official immunity was limited to state law claims, and notably, the defendants did not invoke qualified immunity under Yanero for the plaintiff’s state law claims. The plaintiff's right to adequate medical care as a pretrial detainee is derived from the Due Process Clause of the Fourteenth Amendment rather than the Eighth Amendment. The Eighth Amendment is relevant only post-compliance with constitutional standards for criminal prosecutions. Although the Sixth Circuit acknowledges a potential debate on the protections afforded to pretrial detainees under the Due Process Clause versus the Eighth Amendment, both parties in this case proceeded under the Eighth Amendment framework, thereby waiving any additional protections under the Fourteenth Amendment. The court recognizes that the protections under the Due Process Clause for pretrial detainees are at least equivalent to those under the Eighth Amendment. The court also took judicial notice of World Health Organization data indicating high rates of skilled health personnel attendance during childbirth in the U.S. from 2005 to 2006. Additionally, the court notes a significant shift in societal attitudes towards childbirth locations over the past century, citing a decline in home births from 44% in 1940 to only 0.90% in 2006, with the majority of out-of-hospital births occurring at home. The majority of births in the U.S. occur in hospitals with trained professionals such as doctors, midwives, and nurses present. In 2006, 61% of home births were attended by midwives, and 7.6% by physicians, while 36% were managed by "others," including family members and EMTs, some of whom had training. The Court emphasizes that the concept of "serious medical need" in labor has evolved, noting that births by trained personnel, regardless of location, have become standard. It references past Supreme Court interpretations of the Eighth Amendment, which highlight the need for constitutional principles to adapt over time. Labor symptoms can be subtle and difficult to recognize, but most women are able to identify labor as it progresses, allowing time to seek care. The Court acknowledges personal experiences related to labor timing and emphasizes that a healthy baby was born after an unremarkable delivery, which impacts the damages awarded but does not negate the legitimacy of the alleged injury under the Eighth Amendment. The case cites Coleman v. Rahija to support claims for damages due to pain and suffering related to inadequate medical attention during labor. Additionally, the plaintiff's assertion that Crowe made derogatory comments lacks sufficient evidentiary support, and the Court notes that parties must cite specific evidence in accordance with procedural rules, as judges are not obligated to search the record for it. KRS 71.040 differs from KRS 70.040, which establishes that a sheriff is liable for the actions of deputies, suggesting a legislative waiver of immunity, as supported by Cross, 260 S.W.3d at 345-46. Defendants assert that Kentucky law necessitates physical harm for a negligence claim, referencing the 2002 case Smith v. Franklin County, 227 F.Supp.2d 667 (E.D.Ky. 2002). However, the Smith decision did not conclude that physical harm was required for negligence; rather, it emphasized the necessity of demonstrating causation, specifically that the jail officials' actions led to the alleged injury. Smith's claim of negligence regarding lack of care after a seizure failed because she did not show any lasting injury or impact on her well-being.