Background
Maurice King, a pretrial detainee awaiting sentencing, was assaulted by other inmates in his cell at the Orange County Detention Center. Two detention officers, Berry and Linster, heard moaning and labored breathing from King’s cell but waited approximately twenty-three minutes before entering. They delayed their response to avoid missing a scheduled sensor punch that would have required extra paperwork. King died from injuries sustained during the assault after receiving delayed medical attention.
The court’s reasoning
The court affirmed the denial of qualified immunity for Officers Berry and Linster on the Section one thousand nine hundred eighty-three claim. The officers violated clearly established law by failing to respond to a suspected assault and audible distress. The court found that a reasonable jury could conclude the officers consciously disregarded a substantial risk of serious harm. The court dismissed the appeal regarding the Monell claim and the state bond claim because resolving the qualified immunity issue did not necessarily resolve those claims.
What it means going forward
Detention officers are on notice that delaying medical response to avoid administrative burdens, when they suspect an inmate has been harmed, will not shield them from civil liability.