213755P.pdf   02/03/2023  Jamie Leonard  v.  Steven Harris
   U.S. Court of Appeals Case No:  21-3755
   U.S. District Court for the Eastern District of Missouri - St. Louis   
   [PUBLISHED] [Stras, Author, with Colloton and Wollman, Circuit Judges] 
   Civil case - Civil rights. Jail officers sprayed plaintiff with pepper 
   spray after he refused orders during a search of his cell; he subsequently 
   clawed out his eye while confined in his cell, and he sued the jail 
   officers, staff and jail for violation of his Fourth, Eighth and 
   Fourteenth Amendment rights; the district court granted defendants' motion 
   for summary judgment based on qualified immunity, and plaintiff appeals. 
   Held: The officer's use of pepper spray was objectively reasonable under 
   the circumstances; the officers and nurse who examined plaintiff after he 
   was sprayed did not consciously disregard a serious medical need; decision 
   to place plaintiff in a cell with a sink where he could wash his eyes, as 
   opposed to taking him for additional treatment, was not a constitutional 
   violation; decision by officer who observed plaintiff clawing his eye to 
   await assistance before entering the cell was not deliberate indifference 
   as plaintiff was in a frenzied state, was not handcuffed, and presented a 
   serious safety risk to the officer; denial of plaintiff's medications in 
   these circumstances did not violate clearly established law, and Nurse 
   Martin was entitled to qualified immunity on the claim; on plaintiff's 
   Monell claim, the county did not have a policy or custom of failing to 
   give detainees medication; the district court did not err in determining 
   that no adverse inference should be drawn from the deletion of a video as 
   there was no evidence that the defendants had any intent to deprive 
   plaintiff of the information's use.