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Court Denies Qualified Immunity to Prison Nurses

By Tanya Roth, Esq. on July 13, 2012 | Last updated on March 21, 2019

There's never a shortage of prisoner appeals in the Eighth Circuit. Here's a case involving a prisoner who suffered from active tuberculosis and brought suit against the prison's nurses for failing to recognize his illness.

Prisoner Marchello McCaster was admitted to the Ramsey County Correctional Facility for a 58-day sentence. At the time he was admitted, he had active TB. His condition got worse in prison. Eventually, he was transferred to a hospital ER days before his prison release.

McCaster alleged that the prison's medical staff and administration had been indifferent to his medical needs, so he brought suit under the Eighth Amendment and under Section 1983.

The prison administration benefited from qualified immunity in the district court's decision. The nurses, however, did not have immunity, according to the lower court. They appealed to the Eighth Circuit Court of Appeals.

The Eighth Circuit stated that "qualified immunity shields government officials from liability when their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known."

In order to assert the qualified immunity claim against the nurses, McCaster had to show that the nurses not only knew of his serious medical condition but that they had acted in a manner that amounted to something greater than negligence.

In focusing on these factors, the court came to the conclusion that the record failed to show that two of the nurses had sufficient knowledge of the prisoner's medical condition.

There were, however, three nurses who did have sufficient knowledge and failed to act accordingly. As such, the Eighth Circuit affirmed the district court's denial of summary judgment to those three and remanded the case for further proceedings.

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