Blackmore v. Kalamazoo County.

• Position: PRETRIAL DETENTION - Brief Article

U.S. Appeals Court

MEDICAL CARE

Blackmore v. Kalamazoo County, 390 F.3d 890 (6th Cir. 2004). A former detainee brought an action under [section] 1983 asserting claims under the Eighth and Fourteenth Amendments for failure to provide prompt medical treatment during his detention. The district court granted summary judgment in favor of the defendants, and the detainee appealed. The appeals court reversed and remanded. The court held that summary judgment was precluded by a genuine issue of material fact as to whether the officials' delay in treatment posed a substantial risk of serious harm, where the seriousness of the detainee's appendicitis could be discerned without competent medical proof, and the detainee's manifestations of pain and injury during his...