DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
161341P.pdf 03/07/2017 Dennis Ryan, Jr. v. Officer Mary Armstrong
U.S. Court of Appeals Case No: 16-1341
U.S. District Court for the District of Minnesota - Minneapolis
[PUBLISHED] [Murphy, Author, with Loken and Kelly, Circuit Judges]
Civil case - Civil rights. The plaintiff estate's deceased died while in
custody at the Stearns County Jail, and the estate brought this action for
violation of the deceased's civil rights; the district court erred in
granting defendants summary judgment on plaintiff's deliberate
indifference claim, as a reasonable factfinder could conclude that the
deceased was suffering from an obvious medical need and that the failure
to speak with him or seek medical treatment was a clearly inadequate
response that supports an inference of deliberate indifference
constituting a violation of constitutional rights; the district court
erred in finding that defendants Armstrong and Colluton were entitled to
to qualified immunity given the factors supporting a finding of deliberate
indifference and the case law which shows that it was clearly established
at the time of the incident that a pretrial detainee like the deceased has
a right to be free from deliberately indifferent denials of emergency
medical care; defendants were entitled to summary judgment on the estate's
excessive force claim as the evidence showed that none of the defendants'
actions, either singly or in combination, amounted to an objectively
unreasonable application of force; defendants' summary judgment on failure
to train is reversed in light of the court's ruling on the deliberate
indifference claim; dismissal of the trustee's state law claims is also
reversed. Judge Loken, concurring in part and dissenting in part.