Reed v. Woodruff County

• Jurisdiction: North Carolina

Reed v. Woodruff County

7 F.3d 808 (8th Cir. 1993)

Facts

Plaintiffs, the father and brother of a deceased prisoner, Howard Reed, brought a Section 1983 claim against defendants, Woodruff County, Arkansas, jail officials, charging that they were negligent and violated Reed's constitutional rights and were responsible for his wrongful death. Reed was a trustee prisoner who was incarcerated for failing to appear in municipal court. Prior to his death, when jailer Charlene Smith responded to a jail disturbance, she was told by inmates that they had not seen Reed for some time. Smith checked Reed's cell but could not see him, and he did not answer her verbal calls. Smith returned to the front desk and asked Bobby Bogarth, a City of Augusta police officer and a licensed emergency medical technician, to check Reed's cell. Bogarth found Reed hanging by his neck in the shower stall and determined he was dead. Both officers decided to leave the scene intact pending an investigation into Reed's death. The coroner determined that Reed accidentally killed himself while engaging in autoerotic asphyxiation. The Reeds claimed that Bogarth acted with deliberate indifference to their brother's death and denied him proper medical care by not treating him before determining he was dead. During the course of the litigation, the U.S. District Court for the Eastern District of Arkansas denied the jail officials' motion for summary judgment on the Section 1983 claim and also held that they were not entitled to qualified immunity because the law on deliberate indifference under the Eighth Amendment was already established at the time of the incident. On appeal, the court held that Reed's family failed to point out facts sufficient to show that the officers acted with deliberate indifference to the prisoner's medical needs at the time the officers discovered the prisoner and determined that he was dead. Bogarth, a trained medical technician, testified that he had determined the prisoner was dead.

Issue

Whether the Woodruff County jail officials were entitled to summary judgment in regard to the Eighth Amendment claim that they acted with deliberate indifference to Reed's death by denying him proper medical care before determining he was dead, when they found him hanging in his cell.

Holding for the Eighth Circuit Court of Appeals

The Eighth Circuit Court of Appeals reversed and remanded the case with instructions to grant the county's motion for summary judgment and dismissed the...