In section 1983 action by plaintiff-estate of decedent pre-trial detainee alleging that defendants-prison officials and prison medical personnel violated decedent’s due process rights by failing to timely intervene while decedent underwent hunger strike that resulted in decedent’s death, Dist. Ct. did not err in granting defendants-prison officials’ summary judgment motion, where record showed that said defendants relied reasonably on assurances given by medical professionals that decedent’s medical needs were being taken care of. However, Dist. Ct. erred in entering judgment as matter of law in favor of defendants-medical personnel on issue of causation of decedent’s death, even though Dist. Ct. concluded that there was lack of expert testimony about events that took place during five-day period between decedent’s transfer to hospital and her death. Plaintiff needed only to show that harm from defendants’ inaction with respect to decedent’s hunger strike had diminished plaintiff’s chance of survival, and medical records provided said evidence, where: (1) autopsy ruled out any possibility that decedent died from any hospital-based illness or causes other than starvation and dehydration; and (2) plaintiff’s expert testified that defendants’ delay in transferring decedent to hospital allowed decedent to deteriorate to dangerous point. On remand, plaintiff may proceed on theory that defendants deprived decedent of due process by failing to protect decedent from harming herself. Also, decedent, as pre-trial detainee, need only show that defendants’ decision to continue observing her while she underwent hunger strike was made with purposeful, knowing or reckless disregard of consequences of said delay.
