Anderson v. Calder

Coby Lee Paugh sought help for his chronic alcoholism by turning himself in to the police. The police brought him first to the hospital—where he was given a prescription for Librium and discharged with instructions that he be brought back to the hospital if his condition worsened—and then to the Uintah County Jail. While in jail, Mr. Paugh’s condition deteriorated significantly. The jail officers who were responsible for him, however, did not provide the needed medical assistance. Mr. Paugh died alone in a cell during the night.

Mr. Paugh’s estate sued the officers and the County, alleging that the officers had been deliberately indifferent to his serious medical needs and that their conduct resulted from the County’s policies and customs. The district court denied summary judgment to five of the officers and the County, holding that the officers were not entitled to qualified immunity and that questions of fact precluded summary judgment for the County. On appeal, the Tenth Circuit affirmed the district court’s denial of qualified immunity to the five officers and dismissed the County’s appeal for lack of jurisdiction. With respect to the officers, the court of appeals explained that it was clearly established that ignoring the obvious and serious medical needs of a detainee violates the person’s constitutional rights, and that a reasonable jury could find that the officers disregarded Mr. Paugh’s obvious and serious medical needs. With respect to the County, the court explained that it lacked pendent appellate jurisdiction because the County’s appeal was not inextricably intertwined with the qualified immunity issues.

The five officers and County sought review in the Supreme Court, where Public Citizen served as co-counsel for Mr. Paugh’s estate. The brief in opposition explained that the Tenth Circuit correctly held that the officers violated clearly established law, that the petition identified no circuit split on the issue, and that the Tenth Circuit’s denial of pendent appellate jurisdiction over the County’s appeal did not warrant review. The Supreme Court denied the petition.