Qualified Immunity

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7^th Circuit Court of Appeals

Case Name: Felita McGee v. Larry Parsano

Case No.: 20-2414

Officials: Sykes, Chief Judge, and Manion and St. Eve, Circuit Judges.

Focus: Qualified Immunity

Five days after Carter was booked into the Macon County Jail, he died of diabetic ketoacidosis—a complication of diabetes. In the hours preceding his death, Carter exhibited common symptoms of diabetic ketoacidosis: confusion, lethargy, and labored breathing. But he was denied timely medical care because the jail nurse thought he was faking. She assured the officers tasked with transferring Carter out of the medical unit that his vitals were within a normal range. Relying on the nurse’s medical judgment, the officers declined to intervene and proceeded to relocate Carter, believing that his failure to follow orders stemmed from deliberate refusal, not medically induced incapacity.

The district judge denied the officers’ motions for summary judgment finding there to be a material factual dispute over whether they had reason to know that Carter was receiving inadequate medical care and thus had a duty to intervene.

The appeals court ruled that this case concerns only whether the five corrections officers who transported Carter from the medical unit to the disciplinary unit are entitled to qualified immunity. The corrections officers may reasonably rely on the judgment of jail health professionals, and the qualified-immunity doctrine protects officers from reasonable mistakes when they do so. Accordingly, the corrections officers here are entitled to qualified immunity.

Reversed and Remanded.

Decided 12/15/22

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