Background
Matthew Shelton, a Type-1 diabetic pretrial detainee at Harris County Jail, died from diabetic ketoacidosis after allegedly not receiving insulin or monitoring for four days. Plaintiffs sued Sheriff Ed Gonzalez under Section nineteen eighty-three of Title forty-two of the United States Code, alleging violations of the Fourteenth Amendment due to jail policies and failures to train.
The court’s reasoning
The court addressed jurisdiction under the collateral order doctrine, confirming it could review whether the facts pleaded established a violation of clearly established law without questioning the credibility of those facts. The court found no error in the district court’s denial of qualified immunity, noting that the plaintiffs’ case could proceed against the sheriff under established precedent.
What it means going forward
The ruling allows the wrongful death lawsuit to proceed against the sheriff, subjecting him to discovery and trial on the merits of the qualified immunity defense.