King v. Kramer

Dist. Ct. erred in granting motion for summary judgment by certain defendants-prison officials in section 1983 action alleging that defendants were deliberately indifferent to plaintiff-prisoner's medical condition, where defendants took plaintiff off his current medications and prescribed other drugs that were on prison's drug formulatory, and where plaintiff subsequently incurred seizures that ultimately led to his death. While Dist. Ct. appropriately granted summary judgment with respect to non-medical personnel defendants, who were unaware of medical risks posed by sudden change in plaintiff's drugs, trial issue remained as to defendant-jail nurse, who was subjectively aware that plaintiff faced serious risk of medical emergency and still placed him in isolation so as to preclude him from seeking help from others to request emergency care on his behalf. Moreover, plaintiff presented sufficient evidence to support his claim against defendant-County where, according to plaintiff, defendant had policy that delegated medical decision to third-party entity, which routinely switched prisoners off current prescribed medications without appropriate oversight by physicians.