Background
Jason Thomson died after being restrained by Green Bay police officers at a hospital and transported to a jail. The Estate of Jason Thomson sued the officers and the City of Green Bay under Section nineteen eighty-three of Title forty-two of the United States Code, alleging excessive force and failure to provide medical care. The district court granted summary judgment for the defendants.
The court’s reasoning
The court reviewed the case de novo, viewing facts in the light most favorable to the Estate. Regarding medical care, the court found the officers’ conduct objectively reasonable because they monitored Thomson, confirmed he was breathing, and ensured no one was restricting his airflow, distinguishing this from cases where officers took no action. The court held that the right to medical care must be defined in the specific context of the case, and no clearly established law prohibited the officers’ conduct given the ambiguity of Thomson’s symptoms. Regarding excessive force, the court found the officers’ actions reasonable given Thomson’s combative behavior and the need to restrain him. The court also affirmed the dismissal of the Monell claim because no underlying constitutional violation was found.
Based on what the officers knew at the time and under the circumstances, no reasonable jury could find their conduct objectively unreasonable.
No. 25-2827, slip op. at 9
What it means going forward
The ruling reinforces that officers are not liable for failing to seek immediate medical care when they take reasonable steps to monitor an arrestee’s condition, even if the arrestee complains of breathing difficulties, provided the symptoms are ambiguous.