Currie v. Chhabra

Dist. Ct. properly denied defendants-prison medical officials’ motion to dismiss (on ground of qualified immunity) instant 1983 action alleging that defendants violated plaintiff-arrestee’s constitutional rights by failing to monitor and treat his Type I diabetes, which, in turn, led to plaintiff’s death while incarcerated. Instant complaint properly alleged that claim by plaintiff, as pretrial arrestee who had not yet received probable cause hearing on his misdemeanor charge after plaintiff had been arrested without warrant, was covered by 4th Amendment’s “objectively unreasonable” standard as applied to defendants’ conduct. Moreover, Ct. rejected defendants’ contention that 4th Amendment never applies to constitutional claims alleging inadequate provision of medical care by prison personnel, and further found that instant allegations that plaintiff’s relatives informed defendants of plaintiff’s diabetes diagnosis and yet withheld insulin from plaintiff was sufficient to state viable 4th Amendment claim against defendants.