Taylor v. Stearns County Jail

Background

Taylor alleged that he received constitutionally inadequate medical care after breaking his left wrist during his arrest on March 21, 2014. An emergency department placed his wrist in a splint, prescribed oxycodone, and instructed him to arrange orthopedic follow-up in about five to seven days and return for worsening symptoms.

After police took Taylor to Stearns County Jail, medical care was provided by MEnD Correctional Care, PLLC, whose staff included nurses Elaine Byker, Jodie French, and Ashley Altendahl, and physician’s assistant Martin Langenfeld. Altendahl examined Taylor on March 22. After Taylor was assaulted by another inmate, Byker examined him and notified Langenfeld, but did not order wrist x-rays. Langenfeld first examined the wrist on March 27. He observed discoloration, limited movement, coolness, and delayed capillary refill, but decided not to order additional x-rays or orthopedic follow-up at that time. He continued splinting and pain medication and planned later follow-up.

Taylor was transferred to a Minnesota Department of Corrections facility before that plan’s four-week period ended. On May 6, a nurse ordered x-rays, and an outside orthopedist examined Taylor on May 12. The orthopedist found almost no wrist movement and signs of misalignment and improper healing, recommended surgery, and later reported that the surgery was technically difficult because the wrist had healed in that position.

Claims and motions

Taylor brought claims under 42 U.S.C. § 1983, a federal law allowing claims against people acting under state authority who violate federal constitutional rights. Count One alleged inadequate medical care against the jail, Sheriff Sanner, MEnD, and the MEnD medical workers. Count Two alleged that the jail failed to train its medical staff. Count Three alleged medical negligence against MEnD and its medical professionals.

The jail and Sanner moved for judgment on the pleadings or, alternatively, summary judgment. Because the court considered evidence outside the pleadings, it treated that motion as one for summary judgment. The MEnD defendants moved for summary judgment on Count One.

Court’s analysis

The court held that the MEnD medical workers were not deliberately indifferent to Taylor’s serious medical needs. Deliberate indifference requires more than negligence, a misdiagnosis, or a disagreement over medical treatment; it requires conduct comparable to criminal recklessness. The court concluded that the hospital’s orthopedic instructions were information for Taylor to use in continuing his care, not binding treatment orders that prevented Langenfeld from making an independent medical judgment. Because the medical workers examined Taylor and adopted a treatment plan, the court found that Taylor’s evidence showed, at most, questionable medical decisions or negligence rather than a constitutional violation.

The court also ruled that MEnD could not be liable under § 1983 without an unconstitutional act by one of its employees. The court separately noted that Taylor had not shown the required policy or custom that directly caused a constitutional injury.

The court concluded that Stearns County Jail was not a legal entity that could be sued and granted summary judgment to the jail on Counts One and Two. As to Sanner, the court granted summary judgment on both the official-capacity and individual-capacity claims. The official-capacity claim was treated as a claim against the county, but Taylor had not identified a county policy or custom causing the alleged violations. For the individual-capacity claim, Taylor had not shown Sanner’s personal involvement, knowledge of Taylor’s medical condition, or deliberate indifference.

Disposition

The court ordered that the jail and Sanner’s motion for judgment on the pleadings and/or summary judgment was GRANTED, and dismissed them from the case. It ordered that the MEnD defendants’ motion for partial summary judgment was GRANTED and that Taylor’s § 1983 claim against those defendants was DISMISSED with prejudice. The court stated that all of Taylor’s § 1983 claims were dismissed. Count Three, the medical-negligence claim against MEnD and its medical professionals, remained and was ready for trial. The final order specifically listed MEnD, Langenfeld, French, and Altendahl in the partial-summary-judgment ruling, although the opinion’s analysis also expressly addressed and granted summary judgment to Byker.