Anthony Brown v. Rodney Strain, Jr.

Citations: 663 F.3d 245; 2011 U.S. App. LEXIS 23240; 2011 WL 5600572Docket: 11-30082

Court: Court of Appeals for the Fifth Circuit; November 18, 2011; Federal Appellate Court

Original Court Document: View Document

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Defendants Rodney J. Strain Jr. and Bryan Steinert appeal a district court's partial denial of their summary judgment motion in a case involving Anthony Brown, who was arrested after a traffic stop. During the stop, Steinert found cocaine residue in the vehicle and arrested Brown and his passengers. While in the patrol car, Brown managed to swallow cocaine and a Soma pill. Steinert later reviewed a recording of the suspects’ conversation, but could not determine what had been ingested. At the sheriff’s annex, Lane was found to have additional pills, but no cocaine. Steinert did not check on the suspects’ health or inquire if they needed medical attention. During transport to jail, both Lane and Smith informed Steinert of Brown’s deteriorating condition, stating he needed medical care. Despite their concerns and visible signs of distress from Brown, Steinert only partially opened the windows of the patrol car, indicating inadequate response to the situation. The Fifth Circuit dismissed the appeal due to lack of jurisdiction.

Steinert claims he was unaware of Brown's condition or the need for medical attention until they arrived at the jail, where he first learned that Brown had swallowed cocaine from Lane. Video evidence shows the patrol car arrived at 1:43 a.m., and upon opening the door, Steinert assisted Brown, who was having difficulty standing. At 1:44 a.m., Steinert called for help, and jail personnel arrived. Brown collapsed and displayed shaking from 1:45 a.m. to 1:51 a.m. During this time, although medical equipment was available, jail nurses did not perform medical procedures, and the on-call physician was not contacted. Brown was seated at 1:51 a.m. and remained shaking until an ambulance arrived at 2:09 a.m. While en route, Brown suffered two heart attacks and experienced hyperthermia, leading to anoxic encephalopathy and permanent brain damage. Brown survived but is now totally disabled, cared for by his family. Plaintiffs filed a civil action against St. Tammany Parish Sheriff and Deputies for negligence and deliberate indifference under federal law. The district court granted summary judgment on various claims but allowed the state-law negligence claim and certain federal claims against Steinert and Strain to proceed. The current appeal focuses on these federal claims. The document notes that while summary judgment denials are typically not immediately appealable, those based on qualified immunity are, provided they involve legal issues, as per established legal precedent. The review standard for such appeals differs from typical summary judgment appeals, focusing on the legal significance of the conduct deemed supported by evidence.

Qualified immunity protects public officials from civil liability if their actions do not violate clearly established rights that a reasonable person would recognize. To assess a public official's entitlement to qualified immunity, two inquiries are made: first, whether the plaintiff's allegations demonstrate a violation of a constitutional right, and second, whether that right was clearly established at the time of the alleged misconduct. The right to medical care during pretrial detention was clearly established when Steinert allegedly failed to provide such care to Brown.

A pretrial detainee's right to medical care is infringed if an officer shows deliberate indifference to a substantial risk of serious medical harm. In this case, if plaintiffs can prove that Steinert was deliberately indifferent to Brown's medical needs after he ingested cocaine, Steinert would not be entitled to qualified immunity. 

The plaintiffs' claims are categorized as an "episodic act or omission," as they allege Steinert's specific failure to provide immediate medical treatment. The "deliberate indifference" standard applies here, requiring evidence that Steinert had knowledge of a substantial risk of serious harm, recognized that risk, and responded in a way that suggested he intended harm to occur.

When a district court denies a motion for summary judgment based on qualified immunity, it makes two determinations: one, whether the alleged conduct was objectively unreasonable under established law, and two, whether there is a factual issue regarding the defendant's conduct. The court found that if Steinert knew of Brown's urgent medical needs, his refusal to provide care would be objectively unreasonable. Furthermore, the court identified a genuine issue of material fact regarding Steinert's awareness of Brown's condition, which precludes a jurisdictional review of this determination on appeal.

Steinert's appeal regarding the district court's conclusion on qualified immunity is dismissed due to lack of jurisdiction, as the court can only review legal errors, not factual determinations. Steinert challenges the district court's findings based on the credibility of witnesses and their alleged dishonesty, arguing that this undermines the conclusion of deliberate indifference. However, his arguments do not address whether the established facts could legally support a finding of deliberate indifference. He fails to demonstrate that the claims regarding his awareness of a colleague's drug overdose lacked legal sufficiency to support the plaintiffs' claims or his qualified immunity defense, which are both assessed under the same deliberate indifference standard.

Similarly, the appeal concerning Strain, sued in his official capacity as Sheriff, is also dismissed for lack of jurisdiction. This claim is viewed as one against a municipality, which cannot assert immunity defenses on interlocutory appeal. Strain's request for "pendent appellate jurisdiction" is denied because without jurisdiction over Steinert’s appeal, there is no appealable order for Strain's claim to be linked to. Consequently, both appeals are dismissed for lack of jurisdiction.