Summary Judgement-Causation and Reasonableness

Listen to this article

7^th Circuit Court of Appeals

Case Name: Bettye Jackson v. Sheriff of Winnebago County, Illinois

Case No.: 22-2958

Officials: Flaum, Brennan, and St. Eve, Circuit Judges.

Focus:  Summary Judgement-Causation and Reasonableness

Around 4:36 AM, Simmons, Washington’s cellmate, woke up to the sound of Washington, a pretrial detainee, struggling to breathe. Despite Simmons’ efforts to shake Washington awake, there was no response. At 4:37, Simmons pressed the intercom button, which should have alerted co-defendant Valentine, the control deck officer, through an audible ping and flashing light. However, Valentine did not respond for over a minute, later claiming he misunderstood Simmons, thinking it was about a plumbing issue. After ending the call for about 30 seconds, Simmons tried again around 4:47 to report the emergency. This time, with other officers present, Valentine finally comprehended the seriousness of the situation. They rushed to Washington’s cell at 4:50, promptly called for medical assistance, and began performing CPR. At approximately 4:52, a nurse arrived with a defibrillator and administered an electrical shock. By 5:00, EMTs had arrived and continued CPR. Despite their efforts, Washington was pronounced dead at the hospital. An autopsy revealed that Washington’s death was caused by cardiac arrhythmia triggered by sleep apnea. The district court granted summary judgment for the officer, holding that Jackson had not established causation. Jackson has presented enough evidence at summary judgment to support her claim that the delay diminished Washington’s chances of survival. The Seventh Circuit rules that Jackson has presented enough evidence at summary judgment to support her claim that the delay diminished Washington’s chances of survival. Valentine’s other arguments about the reasonableness of his conduct share the same weakness. As a result, summary judgment would be inappropriate on this basis too

Reverse, Remand.

Decided 07/20/23

Full Text