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.
222582P.pdf 08/15/2023 Carlos Hall, Sr. v. Eric Higgins
U.S. Court of Appeals Case No: 22-2582
U.S. District Court for the Eastern District of Arkansas - Central
[PUBLISHED] [Kelly, Author, with Gruender and Grasz, Circuit Judges]
Civil case - Civil rights. Plaintiff alleged the defendant sheriff was
deliberately indifferent to his medical needs and that he suffered
unconstitutional conditions of confinement and disability discrimination
while he was held in pretrial custody at the Pulaski County jail. On this
record, no reasonable jury could find the jail deliberately disregarded
plaintiff's serious medical needs, and without a constitutional violation,
plaintiff's deliberate indifference claim fails; plaintiff's claim for
unconstitutional conditions of confinement fails because he had not
presented evidence of any official policy that restricts care to disabled
inmates, and the pattern of behavior was not so pervasive or widespread as
to establish an unofficial custom to deny such care; however, plaintiff
has raised a genuine issue of fact with respect to whether the jail
accommodated his access to toilet and bed access or denied him the same
benefits as non-disabled detainees; the district court erred in granting
defendant summary judgment on plaintiff's disability discrimination claim,
and the matter is remanded for further proceedings on this claim.