Background
William P. Brown, a pre-trial detainee in Hillsborough County, Florida, suffered a massive stroke after requesting medical attention on multiple occasions. He sued the county and its sheriff under Section nineteen eighty-three, alleging a pattern of denying medical care to save costs and a failure to properly train jail personnel. The district court dismissed his fourth amended complaint with prejudice for failure to state a claim.
The court’s reasoning
The Eleventh Circuit reviewed the dismissal de novo, construing the pro se complaint liberally but refusing to rewrite deficient pleadings. The court found that Brown abandoned his claim regarding a cost-saving custom and practice by not addressing it in his appellate brief. Regarding the failure to train claim, the court applied the standard from City of Canton v. Harris, requiring facts showing either a pattern of violations or an obvious need for training. The court held that Brown’s allegations of his own stroke did not prove a pattern of violations, nor did they establish that the need for training was obvious to the county.
What it means going forward
The ruling reinforces that plaintiffs must plead specific facts beyond a single incident to prove municipal liability for failure to train under the Eighth Amendment.