Gaines v. Choctaw County Com'n.

• Position: MEDICAL CARE

U.S. District Court

FAILURE TO PROVIDE CARE

DELIBERATE INDIFFERENCE

STAFF

Gaines v. Choctaw County Com'n., 242 F.Supp.2d 1153 (S.D.Ala. 2003). Administrators of a deceased inmate's estate asserted state and federal law claims against a sheriff and county, alleging that the inmate's death resulted from the denial of medical treatment while the inmate was a pretrial detainee in a county jail. The district court held that the county could not be held liable for any alleged lack of training or supervision of the sheriff, or sheriff's employees. The court found that allegations failed to support a claim against the county based on its statutory duty to maintain a jail, but that the allegations supported a claim against the county for an alleged breach of duty to fund medical care, where the alleged failure to provide adequate funding to meet the medical needs of inmates supported a claim for deliberate indifference under [section] 1983. The court noted that although the county did not have a duty to appoint a physician, but merely had the authority to do so, the county had the authority to act and its failure to do so could be construed as a county policy. The court held that the allegations stated a [section] 1983 claim under the Fourteenth Amendment against the sheriff in his individual capacity, based on his direct participation. The sheriff allegedly removed to inmate from the hospital against medical advice, failed to provide adequate treatment during his...