Case Summaries: Fourth Circuit Court of Appeals (May 2023)

This post summarizes published decisions from the Fourth Circuit Court of Appeals released in May 2023. Cases that may be of interest to state practitioners are summarized monthly. Previous Fourth Circuit summaries are available here. Complaint adequately pled a Fourteenth Amendment violation for deliberate indifference to a pretrial detainee’s medical needs and should not have been dismissed Stevens v. Holler, 68 F.4th 921 (May 30, 2023). In this case from the District of Maryland, a pretrial detainee died the day after being released from the Alleghany County Detention Center. His estate sued, alleging a due process violation based on deliberate indifference to the detainee’s medical needs. The district court dismissed the case, finding that the complaint failed to adequately plead that the defendants knew or should have known that failure to provide medical treatment would have created an unreasonable risk of death or serious harm and failed to act. The court unanimously reversed. “Appellant sufficiently alleged that the Individual Medical Defendants knew of and disregarded a substantial risk of serious injury to the Decedent.” Stevens Slip op. at 16. Because dismissal of other claims by the district court was based on the finding that the plaintiff failed to allege a constitutional violation, it was error to dismiss those as well. The case was reversed and remanded for further proceedings. $6 million-dollar damages award against officer for wrongful conviction affirmed; summary judgment in favor of two other officers reversed; summary judgment to the city affirmed Howard v. City of Durham, 68F.4th 934 [...]