Casler v. MEnD Correctional Care, PLLC

Background

Abby Rudolph entered the custody of the Clay County Jail on October 30, 2016, and died fewer than 96 hours later while still in custody. Craig Casler, as trustee for Rudolph’s heirs and next of kin, sought damages for her alleged wrongful death. The opinion addresses claims that correctional officers acted with deliberate indifference to Rudolph’s serious medical needs.

MEnD Correctional Care, PLLC, and Nurse Michelle Pender had settled with Casler and were no longer parties. The remaining defendants addressed in the court’s analysis were Deborah Benson, Jana Bartness, Anthony Hanson, Cassie Olson, Devin Lien, and Lucas Heck. The magistrate judge recommended granting in part and denying in part the defendants’ motion for summary judgment. The defendants objected to the recommendation concerning qualified immunity.

Qualified Immunity Analysis

Qualified immunity is protection from liability for government officials unless the plaintiff shows both a constitutional violation and violation of a right that was clearly established when the alleged misconduct occurred.

The court held that Casler had shown an objectively serious medical need. A medical need can meet that standard when medical evidence supports it or when the need is so obvious that a layperson would recognize the need for a doctor’s attention. The court noted that the recommendation described facts showing that each remaining defendant individually observed circumstances that could lead a layperson to recognize Rudolph’s serious medical need. The defendants did not challenge the evidentiary basis for those facts.

The court also held that genuine disputes of material fact remained about whether each remaining defendant actually knew about Rudolph’s serious medical need and deliberately disregarded it. Because those factual disputes could not be resolved on summary judgment, summary judgment for the remaining defendants was unwarranted on qualified-immunity grounds.

The court further held that the constitutional right at issue was clearly established. Long-standing precedent had established that prison officials may not knowingly disregard a substantial risk of serious harm, including a serious medical need. The court found that the defendants’ cited decision involving a detainee who declined medical assistance did not control because the facts here did not show that Rudolph declined an offer of treatment, and no correctional officer summoned medical staff to meet with her. The court also ruled that Casler did not need to separately prove that the defendants’ conduct “shocked the conscience.”

Disposition

The court overruled the defendants’ objections, adopted the September 28, 2020 report and recommendation, and granted in part and denied in part the defendants’ motion for summary judgment.

The motion was granted as to Julie Savat, Amy Rood, Ryan Magnuson, Amber Nelson, Raynor Blum, Nancy Livingood, Ashley Johnson, Anastacia Hermes, Richard Stetz, Brianna Then, Kari White-Tuton, Joel Torkelson, Justin Roberts, Tiffany Larson, and Clay County, Minnesota. Those defendants were dismissed from the case.

The motion was denied as to Counts I and II against Deborah Benson, Jana Bartness, Anthony Hanson, Cassie Olson, Devin Lien, and Lucas Heck. The opinion does not state the final outcome of those claims.