Background
Plaintiff Shawn Porio was arrested for suspected driving under the influence, but his erratic driving was actually caused by a stroke. A jail intake nurse failed to identify the medical emergency, and Porio was held in custody for over twenty hours before being sent to a hospital, during which time he suffered additional strokes and permanent brain damage. The district court granted summary judgment to the county and a verdict for the nurse, which Porio appealed.
The court’s reasoning
The court held that the plaintiff’s First Amended Complaint and discovery responses adequately alleged a Monell claim based on the county’s failure to train staff on medical screenings for detainees with altered mental status. The court further found that the district court abused its discretion by imposing a strict three-hour time limit on witness examination, which impeded the plaintiff’s ability to present complex medical evidence. Finally, the court determined that the nurse was not entitled to qualified immunity because it was clearly established that officers must provide reasonable medical care when a detainee faces a substantial risk of serious harm.
What it means going forward
The case is sent back to the district court for a new trial against both the county and the nurse, allowing the plaintiff to fully present evidence regarding the county’s training policies and the nurse’s conduct.
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