Reversal of Denial of Summary Judgment Based on Qualified Immunity in Civil Rights Matter
In Youmans v. Gagnon, No. 09-15113, an action alleging that defendant-officer, by booking and questioning plaintiff before seeking medical care for his injuries, was deliberately indifferent to plaintiff's serious medical need in violation of Fourteenth Amendment rights, the denial of summary judgment based on qualified immunity is reversed where neither the "serious medical need" nor the "deliberate indifference" element was established with such clarity that an objectively reasonable police officer in defendant's place would have been on advance notice that defendant's acts in this case would certainly violate the Constitution.
As the court wrote: "This case is about the defense of qualified immunity in situations involving delay in medical care for a pretrial detainee. Plaintiff-Appellee, a pretrial detainee at the time of these events, was beaten (an occurrence in which Defendant-Appellant took no part) in connection with Plaintiff's arrest on robbery charges. He alleges that later Defendant, by booking and questioning Plaintiff before seeking medical care for his injuries, was deliberately indifferent to Plaintiff's serious medical need in violation of Fourteenth Amendment rights."