Background
In 2019, Darren Boykin fled from police in Texarkana, Texas, and died after a chase on a hot summer day. He had sickle cell trait, a condition that increases the risk of sudden death after extreme exercise. Officers transported him to jail, during which he complained of difficulty breathing and eventually lost consciousness. His family sued the officers under Section 1983, alleging deliberate indifference to his medical needs. The district court granted summary judgment based on qualified immunity.
The court’s reasoning
The court applied the deliberate indifference standard, requiring proof that an official actually knew of a substantial risk of serious harm and disregarded it. The court found that Officers Hobbs and Scott could not have known of the risk because they reasonably mistook the symptoms for exercise exhaustion. While a reasonable jury could find that Officer Weaver observed Boykin lose consciousness, the court held that qualified immunity still barred the claim. The court determined that in 2019, it was not clearly established that an officer observing a detainee lose consciousness during transport must immediately secure aid, as controlling precedent on such a duty emerged only in 2021.
It was not clearly established in 2019 that an officer who observes a detainee lose consciousness during transport to jail must immediately secure aid.
Opinion at 2
What it means going forward
The ruling reinforces that officers are afforded latitude when misinterpreting symptoms of serious medical conditions as minor issues, and it clarifies that the duty to provide immediate aid for a detainee losing consciousness during transport was not clearly established law prior to 2021.