11th Circuit Rejects Qualified Immunity to Jailer in Medical Needs Lawsuit

In early April, the Eleventh Circuit found that qualified immunity does not shield jail guards from claims of deliberate indifference to serious medical needs of people in custody, after an Alabama man died from internal bleeding after being kept in a jail cell overnight. Conflicting accounts as to whether the man requested medical help were enough for the court to conclude there was a genuine dispute of material fact to whether the man had a serious medical need.

In Taylor v. Hughes, the Eleventh Circuit rejected the jailer’s claim that he was not aware that the detainee was in a car wreck prior to coming to jail. Rather, the court concluded that “a guard does not need to know a detainee’s specific medical condition to be deliberately indifferent to his or her serious medical need.” “Substantial risk of serious harm” is enough for liability to attach.”

Editor’s Note: the record was devoid of any information that there was a medical assessment performed on the detainee when he was booked into the jail.