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Graham v. Garfield County Detention Center

United States District Court, W.D. Oklahoma

May 24, 2018

JAMES GRAHAM, as Special Administrator for the Estate of Anthony Huff, Deceased, Plaintiff,
GARFIELD COUNTY DETENTION CENTER, an Oklahoma Title 60 authority, et al., Defendants.



         Before the Court is defendant Lela Goatley's (“Goatley”) Motion to Dismiss, filed July 10, 2017. On July 31, 2017, plaintiff filed his response, and on August 8, 2017, Goatley filed her reply.

         I. Introduction

         On June 4, 2016, Anthony Huff was arrested on a public intoxication charge and booked into the Garfield County Detention Center (“GCDC”). While incarcerated at GCDC, Mr. Huff was placed in a restraint chair. Plaintiff alleges that Mr. Huff was in the restraint chair for a period in excess of two days without restroom breaks, medical or mental health treatment, or adequate food or water. On June 8, 2016, Mr. Huff died. On June 6, 2017, plaintiff filed the instant action asserting a negligence claim, an alternative assault and battery claim, and a 42 U.S.C. § 1983 claim. Goatley now moves, pursuant to Federal Rule of Civil Procedure 12(b)(6), to dismiss all claims asserted against her for failure to state a claim upon which relief can be granted.

         II. Standard for dismissal

         Regarding the standard for determining whether to dismiss a claim pursuant to Rule 12(b)(6) for failure to state a claim upon which relief may be granted, the United States Supreme Court has held:

To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face. A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. The plausibility standard is not akin to a “probability requirement, ” but it asks for more than a sheer possibility that a defendant has acted unlawfully. Where a complaint pleads facts that are merely consistent with a defendant's liability, it stops short of the line between possibility and plausibility of entitlement to relief.

Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotations and citations omitted). Further, “where the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct, the complaint has alleged - but it has not shown - that the pleader is entitled to relief.” Id. at 679 (internal quotations and citations omitted). Additionally, “[a] pleading that offers labels and conclusions or a formulaic recitation of the elements of a cause of action will not do. Nor does a complaint suffice if it tenders naked assertion[s] devoid of further factual enhancement.” Id. at 678 (internal quotations and citations omitted). A court “must determine whether the complaint sufficiently alleges facts supporting all the elements necessary to establish an entitlement to relief under the legal theory proposed.” Lane v. Simon, 495 F.3d 1182, 1186 (10th Cir. 2007) (internal quotations and citation omitted). Finally, “[a] court reviewing the sufficiency of a complaint presumes all of plaintiff's factual allegations are true and construes them in the light most favorable to the plaintiff.” Hall v. Bellmon, 935 F.2d 1106, 1109 (10th Cir. 1991).

         III. Discussion

         A. § 1983 claim

         Goatley asserts that plaintiff has failed to state a § 1983 claim against her. Specifically, Goatley contends that plaintiff does not allege that she engaged in any specific actions in violation of Mr. Huff's constitutional rights. Goatley further contends that the only allegation in plaintiff's Complaint directed toward Goatley is that she was “a nurse who worked for Defendant Turn Key [and was] responsible for providing care, monitoring and observing Mr. Huff during the time he was placed in the restraint chair, and ensuring that he had been properly administered his medications.” Complaint at ¶ 11. Goatley also contends that plaintiff has failed to alleged that she was aware of any facts to which she could have been deliberately indifferent.

         In his Complaint, plaintiff alleges that defendants deprived Mr. Huff of rights and privileges afforded to him under the Fourth, Eighth, and Fourteenth Amendments of the United States Constitution in violation of 42 U.S.C. § 1983. Specifically, with respect to Goatley, plaintiff alleges that Goatley was deliberately indifferent to Mr. Huff's serious medical needs.

“Deliberate indifference” involves both an objective and a subjective component. The former is met if the deprivation is “sufficiently serious” - that is, if it is one that has been diagnosed by a physician as mandating treatment or one that is so obvious that even a lay person would easily recognize the necessity for a doctor's attention. The latter is satisfied if an officer knows of and disregards an excessive risk to [a detainee's] health or safety. Essentially, the officer must be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw the inference.

Olsen v. Layton Hills Mall, 312 F.3d 1304, 1315 (10th Cir. 2002) (internal quotations and ...

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