Palmer v. Correct Care Solutions, LLC

291 F. Supp. 3d 1357
CourtDistrict Court, M.D. Georgia
DecidedDecember 5, 2017
DocketCASE NO. 4:17–CV–102 (CDL)
StatusPublished
Cited by8 cases

This text of 291 F. Supp. 3d 1357 (Palmer v. Correct Care Solutions, LLC) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Palmer v. Correct Care Solutions, LLC, 291 F. Supp. 3d 1357 (M.D. Ga. 2017).

Opinion

CLAY D. LAND, CHIEF U.S. DISTRICT COURT JUDGE

One hundred forty-three county jails are spread throughout the state of Georgia, housing tens of thousands of detainees on any given day.1 Many (perhaps most) of these detainees are awaiting trial and have been convicted of no crime. Thus, they are presumed to be innocent. Someone must address their essential needs during their detention, including the provision of constitutionally mandated food and healthcare. Generally, county sheriffs and the county in which these jails are located share that responsibility-the sheriff operates the jail and the county funds it. Although operational and fiscal responsibility may be clearly demarcated under Georgia law, legal responsibility when something goes wrong apparently is not. And thus, the federal reporters are filling up with cases explaining who can be liable when a county jail detainee's federal constitutional rights are violated because of a failure to provide the detainee with essential needs such as food and medical care.

The issue presently before the Court is whether a county detainee may recover money damages in a federal court against a county sheriff in his official capacity to compensate him for injuries he suffered as a result of the violation of his federal constitutional right to receive constitutionally mandated medical care. The resolution of this issue depends upon whether a county sheriff acts as a state officer when he provides medical care in a county jail. If he does, the Eleventh Amendment to the United States Constitution protects him from liability in his official capacity in federal court.

The implications of a ruling that shields a county sheriff from liability for his unconstitutional conduct in the operation of a county jail are significant. Such a ruling would deprive a detainee in a county jail who is injured because of the conscious indifference to his medical needs by the county sheriff of a meaningful remedy in federal court against the sheriff for this federal constitutional violation. And if a finding that the sheriff is a state actor *1360means that he is not a county actor, the detainee may also have no remedy against the county pursuant to 42 U.S.C. § 1983.2 The undersigned previously rejected the notion that neither the county nor the county sheriff could be liable for money damages arising from the failure to provide constitutionally mandated medical care to a county detainee in a county jail. See Youngs v. Johnson , No. 4:06-CV-19 (CDL), 2008 WL 4816731, at *7-*8 (M.D. Ga. Oct. 30, 2008). But the Eleventh Circuit has laid additional bricks in the "immunity wall" since the Court rendered that decision, and in light of recent Eleventh Circuit precedent, it appears that the Eleventh Amendment blocks a detainee from vindicating his federal constitutional rights against a Georgia sheriff under such circumstances. See Lake v. Skelton (Lake I) , 840 F.3d 1334, 1339-42, reh'g denied 871 F.3d 1340 (11th Cir. 2017) (en banc) (holding that a Georgia sheriff acts as an arm of the state when he provides food to county detainees in a county jail).3 Although the Eleventh Circuit has not yet held that a Georgia sheriff is protected by the Eleventh Amendment for his failure to provide constitutionally mandated medical care to county jail detainees, a constitutional claim arising from the failure to provide food, which the Eleventh Circuit held in Lake I cannot be asserted against a Georgia sheriff in his official capacity in federal court because of the Eleventh Amendment, appears indistinguishable for Eleventh Amendment purposes from a claim arising from the failure to provide medical care.

Plaintiff Quintin Palmer suffers from sickle cell disease. Palmer alleges that he did not receive adequate medical treatment while he was a detainee at the Muscogee County Jail and that he suffered serious injuries as a result. He sued those parties who he claims are legally responsible for his injuries, including the Muscogee County Sheriff and his commanding officer in the county jail. Palmer sued the sheriff and his commander in their official and individual capacities. They seek dismissal of the official capacity claims based on Eleventh Amendment immunity.

Palmer makes a compelling argument that the Eleventh Amendment was never intended to shield a county sheriff and his officers from liability arising from their failure to provide adequate, constitutionally mandated medical care to those persons entrusted to their care. But Eleventh Amendment precedent in this Circuit has evolved to provide an almost insurmountable wall protecting Georgia sheriffs sued in their official capacities for violating the federal constitutional rights of county jail detainees. Whether that precedent is well-reasoned is of no concern to this Court; the Court is duty bound to apply it. Based on that precedent, this Court must find that the sheriff and his jail commander are entitled to Eleventh Amendment immunity on Palmer's official capacity claims. Their motions to dismiss those claims (ECF Nos. 2 & 17) are therefore granted.

*1361DISCUSSION

Under the Eleventh Amendment to the U.S. Constitution, "[a] state is immune from a suit for damages in federal court by one of its own citizens." Lake I , 840 F.3d at 1337 (citing Hans v. Louisiana , 134 U.S. 1, 14-17, 10 S.Ct. 504, 33 L.Ed. 842 (1890) ). Many courts have explained the ideological rationale for the Eleventh Amendment. The Amendment " 'is rooted in a recognition that the States, although a union, maintain certain attributes of sovereignty,' and a purpose of the Eleventh Amendment is to 'accord[ ] the States the respect owed them as members of the federation' and not to affront the 'dignity' or 'integrity' of a state by requiring a state to respond to lawsuits in federal courts." Manders v. Lee , 338 F.3d 1304, 1327-28 (11th Cir. 2003) (en banc) (alteration in original) (quoting Hess v. Port Auth. Trans-Hudson Corp.

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Cite This Page — Counsel Stack

Bluebook (online)
291 F. Supp. 3d 1357, Counsel Stack Legal Research, https://law.counselstack.com/opinion/palmer-v-correct-care-solutions-llc-gamd-2017.