Hanes v. Sherburne County Jail

Background

Joshua Cameron Hanes sued Sherburne County Jail; MenD, Inc.; Joel Brott; Thomas Zerwas; Pat Carr; Deanna McMasters; Diana Van DerBeek; and John Doe 1 and 2 under 42 U.S.C. § 1983, a federal law allowing claims against people acting under state authority for violating constitutional rights. Hanes represented himself.

Hanes alleged that he was recovering from surgery after multiple gunshot wounds when he was arrested and transferred to the Ramsey County Workhouse. He alleged that jail staff initially failed to provide adequate assistance, that Deanna McMasters confiscated his prescribed opioid medication and tapered his pain medication, and that healthcare staff did not provide enough help with transfers, showering, toileting, and changing dressings. He also alleged that jail staff dismissed his reports that his leg was bending and that he later required additional surgery.

The County Defendants—Sherburne County Jail, Joel Brott, Thomas Zerwas, and Pat Carr—moved to dismiss for failure to state a claim and moved to stay discovery while that motion was decided. The Healthcare Defendants—Deanna McMasters and Diana Van DerBeek—moved to dismiss for insufficient service of process and failure to state a claim. The court noted that service was no longer disputed as to the Healthcare Defendants because they waived service.

Legal standard

Because the alleged events occurred while Hanes was a pretrial detainee, the court said his medical-care claim arose under the Fourteenth Amendment, while applying the deliberate-indifference standard used for prisoners’ medical-care claims under the Eighth Amendment. That standard requires a serious medical need and facts showing that defendants knew about the need and deliberately disregarded it. Deliberate indifference requires more than negligence or gross negligence; the conduct must show intentional maltreatment or refusal to provide essential care.

On a motion under Federal Rule of Civil Procedure 12(b)(6), the court accepts the complaint’s factual allegations as true and views them favorably to the plaintiff. The complaint must contain enough specific facts to make the claim plausible, rather than merely possible or speculative. The court also said it would read a self-represented litigant’s pleadings liberally but would not assume facts that were not alleged.

Analysis

Sherburne County Jail. The court held that county jails are not legal entities that can be sued. Hanes conceded that dismissal of the jail was appropriate on that basis. The County Defendants’ motion was therefore granted as to Sherburne County Jail.

Healthcare Defendants. The court rejected Hanes’s claim that McMasters and Van DerBeek were deliberately indifferent by tapering him off prescribed oxycodone and providing alternative pain medication. The court stated that an individualized decision to taper an addictive medication generally does not show deliberate indifference, while recognizing that refusing medication solely under a uniform policy could present a different question. Taking Hanes’s allegations as true, the court concluded that the decision to taper his oxycodone did not amount to deliberate indifference or a constitutional violation.

The court also concluded that Hanes had not plausibly alleged intentional maltreatment based on the alleged lack of assistance with daily activities, including showering and toileting. It therefore dismissed the claim against the Healthcare Defendants.

Brott, Carr, and Zerwas. Hanes did not allege that these defendants personally participated in denying medical care. Instead, he relied on their supervisory responsibilities. The court treated the claims against them as official-capacity claims under the rule governing municipal liability. Because the court found no plausibly alleged underlying constitutional violation, it held that municipal liability could not attach and dismissed the claims against Brott, Carr, and Zerwas.

Order

The court granted the County Defendants’ Motion to Dismiss. It granted the Healthcare Defendants’ Motion to Dismiss. It denied the Motion to Stay Discovery as moot. The court dismissed the Complaint with prejudice and directed that judgment be entered.