DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
214016P.pdf 01/31/2023 Donna Reece v. S. Williams
U.S. Court of Appeals Case No: 21-4016
U.S. District Court for the Western District of Arkansas - Fayetteville
[PUBLISHED] [Arnold, Author, with Smith, Chief Judge, and Stras, Circuit
Judge]
Civil case - Civil rights. Plaintiff's decedent, Mr. Reece, died after
being arrested and taken to the Benton County Jail after he allegedly
swallowed a quantity of methamphetamine, and plaintiff alleged the
defendants were indifferent to his serious medical needs; the district
court denied defendants' motion for summary judgment based on qualified
immunity, and they appeal. The district court did not err in holding that
no reasonable juror would find that Mr. Reece's behavior during booking at
the jail would have indicated a serious medical need; however, the
district court erred in denying defendant Williams' motion for summary
judgment based on its conclusion that Williams was told at booking that
Mr. Reece had seizure-like activity on the way to the jail and the
condition was a serious medical condition that Williams deliberately
ignored; there is no authority clearly establishing that a jailer in
circumstances sufficiently similar to these was obligated to summon
medical assistance or relate to others what he had learned from the
arresting officer; other jail defendants were entitled to rely on the
opinion of medical staff as to Mr. Reece's condition, and they were
entitled to qualified immunity; defendant McCain was also entitled to rely
on the opinion of medical staff, and the record does not show she was
deliberately indifferent to Mr. Reece's medical needs; as a result, she
was entitled to qualified immunity.