Davis v. Pulaski County Arkansas

District Court, E.D. Arkansas·Decided July 8, 2021·No. 4:19-cv-00643·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

REGINALD DAVIS PLAINTIFF

v. Case No.: 4:19-cv-643-LPR

PULASKI COUNTY ARKANSAS, et al. DEFENDANTS ORDER Pending before the Court is a Motion for Summary Judgment by separate Defendants Sheriff Eric Higgins, Sergeant Andrew McEwen, Deputy Debra Dillard, Sergeant Nicole Nelson, and Pulaski County, Arkansas (collectively, the “County Defendants”).1 Plaintiff Reginald Davis sued the County Defendants under 42 U.S.C. § 1983.2 He alleges the County Defendants acted with deliberate indifference with respect to his serious medical needs and thus violated his Eighth Amendment right to be free from cruel and unusual punishment.3 The County Defendants move for summary judgment, arguing that Mr. Davis’s failure to establish a constitutional violation forecloses both his individual capacity claims and official capacity claims, including his failure- to-train claim.4 The Court agrees with the County Defendants and therefore GRANTS summary judgment to the County Defendants. I. Procedural Background This case began with seven defendants: Pulaski County, Arkansas; Sheriff Eric Higgins; Deputy Debra Dillard; Sergeant Nicole Nelson; Sergeant Andrew McEwen; Turn Key Health

1 Defs.’ Mot. for Summ. J. (Doc. 32). The Court notes that the record does not definitively establish Nicole Nelson’s rank. For the purposes of this Order, the Court will refer to Ms. Nelson as Sergeant Nelson. 2 Pl.’s Compl. (Doc. 1) at 1. 3 Id. 4 Defs.’ Mot. for Summ. J. (Doc. 34) ¶ 4. Clinics, LLC (“Turn Key”); and Deirdra Vester, LPN (“Nurse Vester”).5 Mr. Davis alleged that Deputy Dillard, Sergeants Nelson and McEwen, Nurse Vester, and Turn Key acted with deliberate indifference towards him when they did not properly attend to his seriously injured ankle.6 Mr. Davis also brought a medical malpractice claim against Turn Key and Nurse Vester, alleging that they administered the wrong insulin medication to him and failed to provide adequate care to him

subsequent to his ankle injury.7 Finally, Mr. Davis alleged that Pulaski County, through its sheriff, failed to properly train its staff on how to deal with inmates’ medical needs.8 Turn Key and Nurse Vester prevailed on two motions, which, taken together, eliminated them from the case. Before discovery, Turn Key and Nurse Vester moved to dismiss Mr. Davis’s Complaint.9 The Court dismissed without prejudice the § 1983 claims against Nurse Vester and Turn Key, finding that those claims did not state viable causes of action.10 With respect to the § 1983 claim that Nurse Vester violated the U.S. Constitution by giving Mr. Davis the wrong insulin, the Court dismissed that claim without prejudice because the allegations were only that Nurse Vester had made a mistake.11 With respect to the § 1983 claim that Mr. Davis was not properly

cared for after he injured his ankle, the Court explained that the Complaint did not allege that Nurse Vester was part of the Turn Key group that responded to Mr. Davis’s ankle injury.12 As for the § 1983 claims against Turn Key, the Court dismissed those claims without prejudice because Mr. Davis never alleged the existence of a Turn Key policy, custom, or practice that was the

5 Pl.’s Compl. (Doc. 1). 6 Id. ¶¶ 50, 51. 7 Id. ¶¶ 22, 67, 69, 70. 8 Id. ¶¶ 52, 53. 9 Defs.’ Mot. to Dismiss (Doc. 5). 10 Order (Doc. 17). 11 Id. at 5. 12 Id. at 5–6. moving force behind the alleged constitutional violation.13 Moreover, Mr. Davis never alleged that Turn Key failed to train or supervise its staff.14 In its dismissal Order, the Court made clear that Mr. Davis might be able to fix the pleading failures in his Complaint, and the Court gave Mr. Davis 45 days to amend his Complaint.15 Mr. Davis did not amend his Complaint. Near the end of discovery, Turn Key and Nurse Vester moved for summary judgment on

Mr. Davis’s medical malpractice claims, arguing that Mr. Davis could not prevail on those claims without a medical expert’s opinion.16 Applying Arkansas law, the Court agreed with Turn Key and Nurse Vester and granted summary judgment in their favor.17 With Turn Key and Nurse Vester out, Mr. Davis’s current case is of necessity focused only on the County Defendants. Mr. Davis brings individual capacity claims against Deputy Dillard and Sergeants Nelson and McEwen.18 Mr. Davis brings official capacity claims against all County Defendants.19

II. Legal Standard Summary judgment is appropriate when there is no genuine dispute as to any material fact and the moving party is entitled to judgment as a matter of law.20 Conversely, if the nonmoving party can present specific facts by “affidavit, deposition, or otherwise, showing the existence of a genuine issue for trial,” then summary judgment is not appropriate.21 It is important to understand

13 Id. at 6–7. 14 Id. at 7–8. 15 Id. at 1–2, 12. 16 Order (Doc. 41) at 1. 17 Id. 18 Pl.’s Compl. (Doc. 1) ¶¶ 6, 7, 8. 19 Id. ¶ 4–8. 20 Torgerson v. City of Rochester, 643 F.3d 1031, 1042 (8th Cir. 2011) (citing FED. R. CIV. P. 56). 21 Grey v. City of Oak Grove, Mo., 396 F.3d 1031, 1034 (8th Cir. 2005). that “[t]he mere existence of a factual dispute is insufficient alone to bar summary judgment.”22 To prevent summary judgment, the dispute of fact must be both genuine and material.23 A genuine dispute of fact exists where a rational juror could decide the particular question of fact for either party.24 A material dispute of fact exists where the juror’s decision on the particular question of fact determines the outcome of a potentially dispositive issue under the substantive law.25

The moving party must show that (1) there is an absence of a genuine dispute of material fact on at least one essential element of the nonmoving party’s case and (2) the absence means that a rational juror could not possibly find for the nonmoving party on that essential element of the nonmoving party’s case.26 If the moving party meets that burden, the burden then shifts to the nonmoving party to show that there is a genuine dispute of material fact.27 The nonmoving party meets that burden by designating specific facts in affidavits, depositions, answers to interrogatories, admissions, or other record evidence that shows “there is a genuine issue for trial.”28 The Court must view the evidence in the light most favorable to the nonmoving party and give the nonmoving party the benefit of all reasonable inferences.29 Accordingly, for purposes of

the Motion here, the Court considers the most pro-plaintiff version of the record that a rational juror could conclude occurred.

22 Holloway v. Pigman, 884 F.2d 365, 366 (8th Cir. 1989). 23 Id. 24 Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). 25 Id. 26 Celotex Corp. v. Catrett, 477 U.S. 317, 322–23 (1986). 27 Matsushita Elec. Indus. Co., Ltd. v. Zenith Radio Corp., 475 U.S. 574, 585–87 (1986); Torgerson, 643 F.3d at 1042. 28 Celotex Corp., 477 U.S. at 322–24. 29 Pedersen v. Bio-Med Applications of Minn., 775 F.3d 1049, 1053 (8th Cir. 2015). III. Facts On July 8, 2017, the Little Rock Police Department arrested Mr.

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Davis v. Pulaski County Arkansas, (E.D. Ark. 2021).

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