Law School Case Brief
Doe v. Gustavus - 294 F. Supp. 2d 1003 (E.D. Wis. 2003)
While placing a prisoner in segregated confinement is not, in itself, cruel and unusual punishment, putting a late term pregnant woman in such confinement is something different.
Plaintiff Jane Doe, a former inmate, brought an action under 42 U.S.C.S. § 1983 against ten defendants, all of whom were security or nursing staff members at the Taycheedah Correctional Institute for women in Fond du Lac, Wisconsin. Plaintiff alleged that each defendant was deliberately indifferent to her serious medical needs while she was in custody. Specifically, many defendants allegedly ignored her cries for help and her medical needs while she went into labor in April 2001. Nursing supervisor Holly Meier was also implicated for failure to adequately train the nurses who treated plaintiff. Defendants filed a motion for summary judgment on the grounds that there was no basis to find deliberate indifference, that two defendants had legitimate institutional objectives in their motives, and that they were all entitled to qualified immunity.
Were all defendants entitled to qualified immunity?
According to the findings of the appellate court, defendants did not seriously contest the issue of medical seriousness. The court held that the recurring theme of the allegations against the nurses was that they dropped the ball so egregiously that the only reasonable explanation was that they knowingly disregarded the risks to plaintiff, the inmate. There was no direct evidence of their subjective mental state. However, plaintiff's expert's testimony, if credited, would invite the jury to make the first of a series of logical inferences required for plaintiff. Construing the evidence in the light most favorable to plaintiff, a reasonable jury could have found in her favor. The court posited that dismissal on summary judgment was unwarranted as to four guards. As to each, there was evidence in the record from which a jury could have reasonably found that he or she deliberately ignored plaintiff's medical condition and suffering. With regard to the guard supervisor, a reasonable jury could have found that putting a late term pregnant inmate into segregation was cruel and unusual punishment. The failure to train claim against the nursing supervisor, however, was inconsistent with the theory of the case. Thus, defendants' summary judgment motion was granted as to the nursing supervisor, but denied in all other respects. The court held that the remaining defendants were not entitled to qualified immunity.
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