Christian v. Wagner, No. 09-2417

Civil Rights Action Alleging Medical Indifference

In Christian v. Wagner, No. 09-2417, an action by a former pretrial detainee at the Johnson County (Iowa) Jail, against several jail employees in their individual capacities, alleging that plaintiff suffered an adverse reaction to a cleaning product used at the jail, the court affirmed judgment for defendants where 1) the jury reasonably determined that plaintiff failed to establish a serious medical need while incarcerated; and 2) the district court did not err by not instructing the jury on a conditions of confinement claim distinct from a claim based on denial of medical care.

As the court wrote:  "Peter Christian, a former pretrial detainee at the Johnson County (Iowa) Jail, brought an action under 42 U.S.C. § 1983 against several jail employees in their individual capacities. Christian alleged that he suffered an adverse reaction to HDQ Neutral, a cleaning product used at the jail. The district court instructed the jury to decide whether the defendants were deliberately indifferent to a serious medical need. The jury found in favor of the defendants, and the district court denied Christian's renewed motion for judgment as a matter of law and for a new trial. We affirm."

Related Resources

• Read the Eighth Circuit's Decision in Christian v. Wagner, No. 09-2417