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Jones v. Faulkner County

United States District Court, E.D. Arkansas, Western Division

October 20, 2014




Russell E. Jones ("Jones") brings this action pursuant to 42 U.S.C. § 1983 against Faulkner County, Arkansas (the "County") and County officers, sued in their individual and official capacities, alleging that he received inadequate medical care during his detention at the County Jail. Jones also brings supplemental claims pursuant to state law. Before the Court is Defendants' motion for summary judgment (ECF Nos. 9, 10, 11), Jones's response in opposition (ECF Nos. 13, 14, 15), and Defendants' reply (ECF No. 16). Also before the Court is Jones's motion to amend (ECF No. 17), Defendants' response in opposition (ECF No. 18), and Jones's reply (ECF No. 19). After careful consideration, and for reasons that follow, Defendants' motion for summary judgment is granted, and Jones's motion to amend is denied. Jones's claims brought pursuant to § 1983 are dismissed with prejudice, and his state law claims are dismissed without prejudice pursuant to 28 U.S.C. § 1367(c)(3).


Summary judgment is appropriate when "the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed.R.Civ.P. 56(a). As a prerequisite to summary judgment, a moving party must demonstrate "an absence of evidence to support the non-moving party's case." Celotex Corp. v. Catrett, 477 U.S. 317, 325 (1986). Once the moving party has properly supported its motion for summary judgment, the non-moving party must "do more than simply show there is some metaphysical doubt as to the material facts." Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986).

The non-moving party may not rest on mere allegations or denials of his pleading but must come forward with specific facts showing a genuine issue for trial. Id. at 587. "[A] genuine issue of material fact exists if: (1) there is a dispute of fact; (2) the disputed fact is material to the outcome of the case; and (3) the dispute is genuine, that is, a reasonable jury could return a verdict for either party." RSBI Aerospace, Inc. v. Affiliated FM Ins. Co., 49 F.3d 399, 401 (8th Cir. 1995).


The following facts are taken from the complaint.[1] On October 12, 2012, at approximately 10:35 p.m., Jones was driving home from a high school reunion, when he was pulled over by officer Matthew Hugen ("Hugen"), who suspected that Jones was intoxicated.[2] Jones informed Hugen that he suffered from epilepsy and took prescription medicine to prevent seizures, and he handed his prescribed medications to Hugen.

After the traffic stop, Jones was transported to the Faulkner County Jail, where he was detained for three days and three nights. He alleges that during his detention, he told "deputies" that he suffered from epilepsy and that it was imperative that he take his prescribed medications to prevent seizures. Jones reports that he repeatedly requested his medication, and he gave "deputies" the name of his physician so that jail officials could confirm that he needed his medicine, but "Defendants" refused to contact his pharmacy or his doctor and refused to give him his medicine. Jones further alleges that he suffered multiple seizures, including a convulsive seizure on October 14, 2012, and that "Defendants" responded by placing him a restraint chair.

On October 15, 2012, while Jones was still in custody and restrained in a wheelchair, he appeared before a judge. He alleges that the trauma of repeated seizures left bruises and lacerations on his head and body, and his friend, who was present in the courtroom, noticed his injuries and took him to a hospital for treatment. Jones alleges that physicians confirmed that he had suffered repeated seizures that caused injuries, which would have been prevented if he had taken his anti-seizure medicine during his three-day detention.


On October 4, 2013, Jones filed this action pursuant to 42 U.S.C. § 1983. In his complaint, Jones identifies four defendants: the County; Andy Shock ("Shock"), the Faulkner County Sheriff; and John Randall ("Randall") and Lloyd Vincent ("Vincent"), officers of the Faulkner County Sheriff's Department. Jones also lists ten John or Jane Doe defendants, and he seeks leave to file an amended complaint that identifies the Doe defendants by name. Jones sues each defendant individually and in his or her official capacity, and he charges that they failed to provide him constitutionally adequate medical care during his detention at the County Jail. Jones also brings supplemental, state law claims.

The named and identified defendants, who have been served in this case, move for summary judgment. Shock, Randall, and Vincent assert that they are entitled to qualified immunity with respect to Jones's individual-capacity claims, brought pursuant to § 1983, and the County asserts that Jones is unable to come forward with evidence of an unconstitutional County policy, custom, or usage necessary to impose liability under § 1983.

42 U.S.C. § 1983 - Individual-Capacity Claims

Qualified immunity shields government employees acting within the scope of their duties from suit so long as their conduct does not "violate clearly established statutory or constitutional rights of which a reasonable person would know." Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982). Two questions guide the determination of whether a defendant is entitled to qualified immunity as to claims brought against him in his individual capacity. The first is whether the facts, viewed in a light most favorable to the plaintiff, show that the defendant's conduct violated a federal constitutional or statutory right. Saucier v. Katz, 533 U.S. 194, 201 (2001). If a constitutional right has not been violated, the defendant is entitled to qualified ...

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