Jones v. Muskegon County, 09-2125

Deceased inmate's father's civil rights suit

Jones v. Muskegon County, 09-2125, concerned a challenge to the district court's grant of summary judgment in favor of the defendants, in a deceased inmate's father's action raising a 42 U.S.C. section 1983 claim and state law claims for gross negligence and intentional infliction of emotional distress against members of the medical staff, corrections officers, and the county, for his son's death while incarcerated at the county jail.

In affirming in part, the court held that the district court properly granted summary judgment in favor of the corrections officers on plaintiff's section 1983 claim, as none of the evidence implicates any specific officer and as such, it does not raise a genuine issue of material fact regarding the liability of any officer.  The court also affirmed the district court's grant of summary judgment in favor of the doctor as a reasonable jury would not conclude that the doctor's conduct amounted to "grossly inadequate care," as well as the district court's grant of summary judgment in favor of the county as plaintiff failed to establish a custom of deliberate indifference to the serious medical needs of inmates at the county jail.  Lastly, the court affirmed the district court's grant of summary judgment in favor of all the defendants on plaintiff's state law claims for intentional infliction of emotional distress.

However, the court reversed and remanded the district court's grant of summary judgment in favor of the two of the three nurses, on plaintiff's section 1983 and gross negligence claims, as there is sufficient evidence to raise a genuine issue of material fact regarding whether the two nurses knew of the risk to the deceased inmate's health, yet consciously disregarded the risk;

Related Link:

• Read the Sixth Circuit's Full Decision in Jones v. Muskegon County, 09-2125