Heflin v. Stewart County

• Jurisdiction: United States

Heflin v. Stewart County

958 F. 2d (1992)

Facts

A Section 1983 claim was brought by the family of a twenty-year-old pretrial detainee (Heflin) who committed suicide in the Stewart County, Tennessee, jail. Those sued in the claim included the county, the sheriff (Hicks), one deputy (Crutcher), and the jailer (Hoffman). A jury awarded damages to the plaintiff, and the defendants appealed. The defendants' appeal was based on the fact that the District Court denied their motion for a directed verdict of acquittal at the conclusion of the plaintiff's case. A second attempt was made by the defendant to renew the motion for a directed verdict of acquittal after both sides presented closing arguments. On appeal, the defendants contend that the evidence was insufficient for the submission of two issues: (1) Whether any act or failure to act of the defendants was the proximate cause of the inmate's death; and (2) Whether any defendant acted with "deliberate indifference" to the inmate's medical needs after he was discovered hanging in his cell. The defendants also argued that they were entitled to judgment based on qualified immunity. Stewart County sought reversal, as well on the ground that no county policy or action led to the inmate's death.

Issue

Did the District Court err in denying Sheriff Hicks and Duty Sheriff Crutcher a directed verdict because the evidence did not show that Hicks and Crutcher's response to Heflin's hanging amounted to deliberate indifference to his serious medical needs?

Holding

The Sixth Circuit Court of Appeals affirmed the District Court's ruling, and the jury awarded Heflin's family after finding sufficient evidence to support the action.

Reason

In Heflin, the Court of Appeals cited the U.S. Supreme Court holdings in Bell v. Wolfish and Estelle v. Gamble in that pretrial detainees have a constitutional right to the same protection afforded convicted prisoners who have serious medical needs that cannot be ignored. To ignore the serious medical needs of prisoners would invoke an Eighth Amendment claim of deliberate indifference to the plight of inmates. In this case, the Court of Appeals held that a motion for a directed verdict is granted when it is determined "that reasonable minds could not differ as to the governing facts." When applying this standard, the court stated that "We cannot find that the District Court erred in denying the defendants, Sheriff Hicks and Deputy Crutcher's motion, because no one attempted to resuscitate...