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Bonny Edward Taylorv.Henry P. Hughes, Et Al.

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.17-14772
DecidedApril 3, 2019
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CivilCivil RightsEighth AmendmentQualified ImmunityDue ProcessWrongful DeathReversalRemand
Case Summary

Almus Taylor was arrested after being found injured and unable to walk, then taken to an Alabama jail after declining an ambulance. He died overnight from internal bleeding. His estate administrator sued the jail guards under federal and state law, alleging deliberate indifference to serious medical needs. The district court granted the guards summary judgment based on qualified immunity, state-agent immunity, and a statutory immunity for jail personnel. The Eleventh Circuit reversed and remanded. Viewing disputed facts in the estate’s favor, the court held that the allegations and record could support a finding that the guards were deliberately indifferent to Taylor’s serious medical condition. Qualified immunity therefore could not be resolved for the guards at summary judgment on the constitutional claim. The court likewise held that state-law immunity did not protect conduct that violated federal or constitutional law, and the Alabama jail-guard statute did not require dismissal on the record before the court. The decision leaves factual questions for further proceedings and underscores that officials cannot invoke immunity to avoid trial when the evidence supports a possible failure to respond to an obvious medical emergency.

Opinion

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