Summary Judgment – Qualified Immunity

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7^th Circuit Court of Appeals

Case Name: Gloria Taylor v. City of Milford, et al.,

Case No.: 20-1109

Officials: WOOD, BRENNAN, and ST. EVE, Circuit Judges.

Focus: Summary Judgment – Qualified Immunity

In 2016, Gloria Taylor called 911 seeking medical care for her husband, Steven, who was experiencing a diabetic emergency at their home in Milford, Illinois. Officer Joseph Garrett responded to the call and re‐ strained Steven in a prone position, face down on his bed, for several minutes. Steven vomited and lost consciousness, and he did not regain consciousness before passing away in the hospital ten days after the incident at sixty‐one years old. After the district court granted summary judgment to the Defendants, Plaintiff appealed the district court’s judgment with respect to whether Defendant Garrett was entitled to qualified immunity based on his conduct within the Taylor home. As we explain below, the district court erred in granting qualified immunity to Garrett at the summary judgment stage.

Reversed and remanded

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Derek A Hawkins is Corporate Counsel, at Salesforce.