Cassiopia Rhoads v. Erik Riddell; Jessica Whitaker and Southern Health Partners, Inc.; Robert J. Williams, M.D.; Brandi Galloway; Donna Wright; Chanate Buchanan; Tonetta Buggs; Tamara Erikson
July 2, 2026·25-1860·Panel Decision·Thacker·By James Taylor
The Fourth Circuit affirmed the denial of qualified immunity to two supervisory correctional officers who failed to act on repeated warnings about a detainee's severe medical condition. The court held that the right to adequate medical care for pretrial detainees was clearly established, even when non-medical officers initially deferred to medical staff.
Cassiopia Rhoads was detained at the Aiken County Detention Center from May to June 2019. During her detention, she developed a severe abscess on her head that required medical intervention. Despite multiple complaints from Rhoads and warnings from subordinate officers, supervisory officers Erik Riddell and Jessica Whitaker failed to ensure she received adequate care. Rhoads was eventually placed in solitary confinement, where she lost access to medical request kiosks, and was not transported to a hospital until she was found unconscious. She was later diagnosed with osteomyelitis and epidural abscesses requiring brain surgery.
The court’s reasoning
The court determined that the right of a pretrial detainee to be free from deliberate indifference to serious medical needs was clearly established at the time of the alleged conduct. The court rejected the argument that non-medical officers could automatically defer to medical staff decisions. It found that officers who ignore indications that initial medical treatment is inadequate, especially when faced with manifest symptoms and repeated warnings, can be liable. The court noted that placing the detainee in solitary confinement, thereby cutting off her ability to report medical issues, further supported the finding that the officers’ conduct violated clearly established law.
What it means going forward
The decision reinforces that correctional officers have an independent duty to act when they are aware of a detainee’s serious medical needs, even if medical staff are involved. It clarifies that the mere existence of medical treatment does not shield officers from liability if they ignore clear signs of inadequate care or prevent a detainee from seeking help.
