Williams v. City of Yazoo

Case: 20-61061 Document: 00516395626 Page: 1 Date Filed: 07/15/2022

United States Court of Appeals

for the Fifth Circuit United States Court of Appeals

Fifth Circuit

FILED

July 15, 2022

No. 20-61061 Lyle W. Cayce

Clerk

Kyron La-Trell Williams, a minor, by and through his mother and

natural guardian, Lavina Smith individually and on behalf of all heirs at

law and wrongful death beneficiaries of Marshawn Williams, deceased;

Donnie Williams,

Plaintiffs—Appellees,

Za’Riya Williams; Estate of Marshawn Williams,

Intervenor Plaintiffs—Appellees,

versus

City of Yazoo, Mississippi; Yazoo City Police

Department; Andre Lloyd, individually and in his official capacity;

Patrick Jaco, individually and in his official capacity; Chris Dean,

individually and in his official capacity; Clifton Tilmon, individually

and in his official capacity; Arthur Thompson, individually and in his

official capacity; Officer Artis Harris, individually and in his official

capacity; Officer Kenyon Banks, individually and in his official

capacity; Sharon Vancleave, individually and in his official capacity;

Tracy Langston, individually and in his official capacity,

Defendants—Appellants.

Appeal from the United States District Court

for the Southern District of Mississippi

USDC No. 3:15-CV-103

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Before Clement, Graves, and Costa, Circuit Judges.

Gregg Costa, Circuit Judge:

Marshawn Williams died in his cell at the Yazoo County Detention

Center after bleeding internally for hours. His survivors allege that law

enforcement officials knew that Williams had been assaulted with a metal

pipe and that he was vulnerable to internal bleeding if injured, yet they

ignored requests for help from Williams, his family, and his fellow detainees,

and left Williams to suffer in his cell until it was too late. If these facts are

proven at trial, the officials’ indifference to Williams’s serious medical needs

violated his clearly established constitutional rights. We therefore affirm the

denial of qualified immunity.

I

The parties dispute much of what happened in the hours leading up to

Williams’s death. The following account takes the facts in the light most

favorable to Williams’s survivors, as we must at summary judgment. Tolan

v. Cotton, 572 U.S. 650, 655–56 (2014).

On the evening of his death, Williams and his longtime girlfriend,

Lavina Smith, got into a physical altercation at their Yazoo City, Mississippi

home. A witness alerted both Smith’s family and police.

Smith’s family arrived first. Outraged that Williams had been violent

to his sister, Smith’s brother hit Williams on the side with either a bedrail or

a metal pipe. The two men tussled over the object until Smith’s uncle

intervened and separated them.

Police were not far behind. Sergeant Thompson and Officers Harris,

Dean, and Banks of the Yazoo City Police Department arrived at the home a

few minutes later and split up: Harris and Thompson went inside to speak

with Smith, while Dean and Banks spoke with Williams on the porch.

Williams told Dean and Banks that he had been drinking and that he

and Smith had fought. He also told them that Smith’s brother assaulted him

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with a pipe. He lifted his shirt to show Dean where he had been hit, revealing

superficial scratches. During that conversation, Williams laid down on the

porch as if trying to sleep. Harris joined the group outside, handcuffed

Williams, and informed him that he was under arrest for domestic violence.

Witnesses remember what happened next differently. Smith, who

observed the arrest from the porch, recalls that Williams struggled to walk

and collapsed on his way to the police car. The officers say that he was

passively resisting arrest by forcing them to carry him to the vehicle. Harris

sprayed mace in Williams’s eyes and the officers loaded him into the police

car.

The officers brought Williams to the Yazoo County Detention Center.

Williams was in and out of consciousness during booking. At one point, he

urinated on himself and slumped out of his chair to the ground. He did not

cooperate with the officers’ requests for personal information. Contrary to

jail policy, no officer screened him for medical needs.

Dean and Banks escorted Williams to his cell. Again, Williams needed

assistance walking. Three detainees overheard Williams ask Dean and Banks

for help during the walk to his cell. One recalls Williams telling the officers,

“I need my medical assistance, and I can’t breathe,” and another heard

Williams say “I need some help. I need y’all to call my people, my family so

I can get my medication.” The third similarly remembers Williams

requesting medical help. The officers did not respond to Williams’s pleas.

Meanwhile, Officer Patrick Jaco called Smith to ask if Williams was

sick or on any medication. Smith passed the phone to Williams’s mother,

Donnie, who said that she would come to the jail to discuss the matter.

Donnie was worried because she knew that Williams had been in a scuffle

back at the house and likely needed medical attention.

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At the jail, Donnie, her daughter, and her nephew spoke to Harris,

Jaco, Dean, Banks, and Officer Sharon VanCleave. Jailer Tracey Langston,

who was sitting at a nearby desk, was also present for the conversation. 1

Donnie told the group that Williams was not currently on any

medication. She also told them that Williams “grabbed his side and fell

over” before his arrest. She explained that Williams’s blood does not clot

normally so that “if he got hurt in any kind of way . . . he would just bleed.”

Williams’s sister chimed in, noting that “[H]e could die!” Banks responded

that Williams had passed out twice in front of them, but Dean dismissed his

concerns, suggesting that Williams was merely being uncooperative to avoid

arrest. The officials did not take any action in response to this information.

Once in his cell, Williams repeatedly called for his mother and for

medical attention. He was unable to stand or use the toilet on his own. His

cellmate propped him into a seated position against a wall, and he lost

consciousness there.

For two to three hours, Williams’s fellow detainees banged on their

cell doors and repeatedly yelled to Langston that Williams was having a

medical emergency. Langston asked them to quiet down and told them that

she could not do anything until her superior returned to the jail. She did not

check on the detainees hourly, as required by prison policy.

Around 2:15 a.m., officers found Williams dead in his cell. The

autopsy report concluded that Williams had died of a laceration to his liver

and extensive internal bleeding. It also noted blunt force injuries on the left

side of his torso.

1

The parties dispute whether Langston could hear what Donnie told the officers.

At summary judgment, we credit Donnie’s testimony that Langston was present the

“whole time,” which could support the conclusion that she heard this discussion.

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Williams’s surviving family sued Yazoo City, the Yazoo City Police

Department, and the officers and jailer involved in his arrest and detention.

They contend that the officials violated Williams’s federal rights by falsely

arresting him, using excessive force, and wrongfully denying him medical

care. They further assert that the City violated his federal rights by

inadequately training its employees and maintaining an unconstitutional

policy of the same. Finally, they sued the officials in their official capacities

for related state law torts, including an analogous denial-of-care claim.

The City and individual defendants moved for summary judgment.

The district court dismissed many of the claims but determined that the

federal and state denial-of-care claims and the claims against the City should

be submitted to a jury. In rejecting the officials’ qualified immunity defense

at summary judgment, the district court found numerous fact issues that, if

resolved in the plaintiffs’ favor, would establish their liability on the federal

denial-of-care claim. It did not, however, consider whether that

constitutional violation was clearly established at the time of Williams’s

death.

Believing that the entire suit should have been dismissed, the

defendants appealed.

II

Many defendants would like to appeal, but only some may.

“Ordinarily, we do not have jurisdiction to review a denial of a summary

judgment motion because such a decision is not final within the meaning of

28 U.S.C. § 1291.” Palmer v. Johnson, 193 F.3d 346, 350 (5th Cir. 1999). But

under the collateral order exception to the final judgment rule, we may hear

interlocutory appeals of the “small category of decisions that, although they

do not end the litigation, must nonetheless be considered final” because they

would be effectively unreviewable on appeal from final judgment. Swint v.

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Chambers Cnty. Comm’n, 514 U.S. 35, 42 (1995) (internal quotation omitted).

Because qualified immunity insulates officials from the burdens of litigation,

a benefit that is irretrievably lost if the official prevails at trial, denials of

immunity fall into that narrow category. Mitchell v. Forsyth, 472 U.S. 511,

526–27 (1985). That is why we can review the federal denial-of-medical care

claim against the officials in their individual capacities. See Hafer v. Melo, 502

U.S. 21, 27 (1991).

Yazoo City’s appeal is different. Municipalities do not enjoy qualified

immunity, Owen v. City of Independence, 445 U.S. 622, 638 & n.18 (1980), so

the denial of summary judgment to the City is not an immediately appealable

collateral order, see Swint, 514 U.S. at 43. Lacking a final order, we have no

jurisdiction over the Monell claims.

Yazoo City argues that we nonetheless can hear its appeal because it

is “inextricably intertwined” with the claims against the individual

defendants. But we do not allow municipalities to piggyback on officers’

interlocutory qualified immunity appeals. Zarnow v. City of Wichita Falls, 500

F.3d 401, 407 (5th Cir. 2007) (“[R]efus[ing] to recognize ‘so strange an

animal as pendent party interlocutory appellate jurisdiction.’” (quoting

McKee v. City of Rockwell, 877 F.2d 409, 413 (5th Cir. 1989))); Burge v. Parish

of St. Tammany, 187 F.3d 452, 477–78 (5th Cir. 1999) (rejecting pendent

jurisdiction over Monell claim in qualified immunity appeal); see also Bryan

Lammon, Municipal Piggybacking in Qualified-Immunity Appeals, 126 Pa. St.

L. Rev. 123, 137, 141 (2021) (explaining that while some circuits allow

municipal piggybacking, the Fifth Circuit does not). In other words, our

pendent jurisdiction does not allow us to bring additional parties into an

appeal, even if their claims relate to an issue that is properly before us. Yazoo

City must wait for final judgment to appeal the inadequate training and

unconstitutional policy claims.

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We lack jurisdiction over the state law denial-of-medical-care claim

for the same reasons. Although the claim is nominally against the individual

defendants, they are sued only in their “representative” capacity. See Miss.

Code Ann. § 11–46–7(2). 2 Like federal law, Mississippi law treats official-

capacity officer suits as suits against the employing government entity.

Womble v. Singing River Hosp., 618 So.2d 1252, 1261 (Miss. 1993) (“[S]uing

public officials in their official capacities is tantamount to suing the State or

its affiliated entities themselves.”); Mallery v. Taylor, 805 So.2d 613, 622

(Miss. 2002) (“Unless the action is brought solely against an employee acting

outside of the scope of his employment, the government entity must be

named and sued as the party in interest under the Tort Claims Act.”); see also

Kentucky v. Graham, 473 U.S. 159, 166 (1985) (“[A]n official-capacity suit is,

in all respects other than name, to be treated as a suit against the entity.”)

(internal citation omitted). Yazoo City does not enjoy qualified immunity

and thus has no right to interlocutory appeal.

Accordingly, at this time we consider only the individual defendants’ 3

qualified immunity appeal.

III

Qualified immunity protects officials from civil liability for conduct

that “does not violate clearly established statutory or constitutional rights of

which a reasonable person would have known.” Harlow v. Fitzgerald, 457

U.S. 800, 818 (1982). To overcome the immunity defense, Williams’s

survivors must show both (1) that the officials violated Williams’s statutory

2

Mississippi officers can be personally liable for torts committed beyond the scope

of their employment, see Miss. Code Ann. § 11–46–7(2), but that is not alleged here.

3

For the remainder of the opinion, “defendants” will refer to these individual

defendants, as they are the only ones whose appeal we can consider.

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or constitutional right and (2) that right was clearly established at the time of

the challenged conduct. Ashcroft v. al-Kidd, 563 U.S. 731, 735 (2011).

Although we may review qualified immunity denials on interlocutory

appeal, our review is more limited than our usual summary judgment

practice. We do not decide whether genuine fact disputes exist. Johnson v.

Jones, 515 U.S. 304, 313 (1995). Instead, accepting the plaintiffs’ version of

the facts, we consider only the legal question whether the defendants’ actions

were objectively unreasonable in light of clearly established law. Kinney v.

Weaver, 367 F.3d 337, 346 (5th Cir. 2004) (en banc).

A

The Constitution imposes a duty on the state to provide for the safety

and wellbeing of the people it incarcerates. DeShaney v. Winnebago Cnty.

Dep’t of Soc. Servs., 489 U.S. 189, 199–200 (1989). For people already

convicted of a crime, this duty stems from the Eighth Amendment’s

prohibition on cruel and unusual punishment. Estelle v. Gamble, 429 U.S. 97,

103–05 (1976). For those like Williams, who have not yet faced trial, it stems

from due process instead. See Bell v. Wolfish, 441 U.S. 520, 535–37 (1979).

The state’s obligation is the same in both contexts: 4 It must provide for

4

The Supreme Court recognizes that pretrial detainees’ right to medical care is

“at least as great” as that of convicted prisoners, City of Revere v. Mass. Gen. Hosp., 463

U.S. 239, 244 (1983), but has never defined the contours of that right, see City of Canton v.

Harris, 489 U.S. 378, 388 n.8 (1989) (leaving the question open). We are in the “slight

majority” of circuits that apply the Eighth Amendment standard equally to denial-of-care

claims by pre- and post-trial detainees. David C. Gorlin, Note, Evaluating Punishment in

Purgatory: The Need to Separate Pretrial Detainees’ Conditions-of-Confinement Claims from

Inadequate Eighth Amendment Analysis, 108 Mich. L. Rev. 417, 426 & 428 n.71 (2009);

see also Catherine T. Struve, The Conditions of Pretrial Detention, 161 U. Pa. L. Rev. 1009,

1024 (2013) (observing a trend toward this approach). The minority approach grants

pretrial detainees broader protections because they have not yet been found guilty. Gorlin,

supra, at 426 n.54, 427–28; see also Bell, 441 U.S. at 535 (explaining that pretrial detainees

cannot be held in punitive conditions).

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detainees’ “basic human needs,” including “food, clothing, shelter, medical

care, and reasonable safety.” DeShaney, 489 U.S. at 200; see also Hare v. City

of Corinth (“Hare II”), 74 F.3d 633, 639 (5th Cir. 1996) (en banc) (extending

this standard to the pretrial detention context).

The Fourteenth Amendment thus bars law enforcement from

responding to a detainee’s serious medical needs with deliberate

indifference. Farmer v. Brennan, 511 U.S. 825, 828 (1994); see also Hare II,

74 F.3d at 647–48. To prove deliberate indifference, Williams’s survivors

must show that the defendants knew that he faced a substantial risk of serious

harm and failed to take reasonable measures to abate that risk. Farmer, 511

U.S. at 847. The knowledge inquiry is subjective. We ask what the officials

knew, not what they “should have perceived but did not.” Id. at 838. 5 But

the reasonableness question is objective: It turns on whether the officials’

response to a known risk was reasonable as a matter of law. Hare v. City of

Corinth (“Hare III”), 135 F.3d 320, 327–28 (5th Cir. 1998). We consider each

defendant’s knowledge and response individually. See Mason v. Lafayette

City-Parish Consol. Gov’t, 806 F.3d 268, 279 (5th Cir. 2015).

Taking Williams’s allegations as true, Dean and Banks were aware of

a substantial risk to Williams’s health. Williams’s family was so concerned

about him that they came to the station to tell law enforcement about his

medical vulnerability. Williams’s mother informed them that Williams

5

The defendants assert that the risk to the detainee must be “obvious.” It is true

that “[w]e have found deliberate indifference when the plaintiff alleges facts of an apparent

or obvious risk to a prisoner’s health.” Estate of Cheney v. Collier, 560 F. App’x 271, 273–

74 (5th Cir. 2014) (unpublished). But this is just one way of proving that an official had

actual awareness of a serious medical need. See Farmer, 511 U.S. at 842 (“[K]nowledge of

a substantial risk is a question of fact subject to demonstration in the usual ways, including

inference from circumstantial evidence[.]”). If an official has subjective knowledge of a

risk, it does not matter whether that risk would be obvious to anyone else.

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suffered from a preexisting and life-threatening blood clotting condition that

would cause him to bleed internally if he was “hurt in any kind of way.” And

Williams’s sister reiterated to them how serious the condition was,

explaining that Williams “could die” if injured.

In addition to knowing of Williams’s diagnosis, Dean and Banks knew

that Williams was hurt. When they first talked to Williams, he told them that

he had been hit in the side with a metal pipe. Williams’s mother later

reminded them that he “grabbed his side and fell over” before his arrest.

Dean and Banks also witnessed Williams struggling to walk and were aware

that he passed out at least twice during his arrest and booking. If any doubt

remained about Williams’s need for care at that point, it was eliminated when

Williams told Dean and Banks that he could not breathe and asked them for

medical assistance while they escorted him to his cell. Contrast Pearson v.

Prison Health Serv., 850 F.3d 526, 540 (3d Cir. 2017) (concluding that officer

had no knowledge of risk because plaintiffs did not present any evidence

“that the seriousness of [the detainee’s] bleeding was communicated to

her”).

If these allegations are proven, this is not a close case: Williams’s

diagnosis, symptoms, and requests for help notified Dean and Banks of a

significant risk that he was bleeding internally. See Easter v. Powell, 467 F.3d

459, 463–65 (5th Cir. 2006) (finding knowledge of risk based on combination

of known heart condition, complaints of chest pain, and request for

medication); Harris v. Hegmann, 198 F.3d 153, 159–60 (5th Cir. 1999)

(finding knowledge based on recent broken jaw diagnosis, complaints of pain,

and requests for treatment).

The evidence construed in plaintiffs’ favor would also allow a jury to

find that Harris, Jaco, and VanCleave knew of Williams’s serious medical

situation. Like Dean and Banks, they were informed by Williams’s family

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that he had a blood clotting condition that made any injury potentially fatal.

They also saw Williams lose consciousness during booking. Unlike Dean and

Banks, they did not know exactly how Williams had been injured—they only

knew from his mother that he “grabbed his side and fell over.” Although

they did not know the full severity of Williams’s injuries, a jury could find

that the risk was obvious. See Farmer, 511 U.S. at 842. Falling over can

indicate a serious condition, particularly given Williams’s symptoms, his

family’s grave concerns, and the officers’ knowledge that “any kind” of

injury could kill him. A jury could conclude that the officers put the clues

together and were aware that Williams might be harmed. See Nerren v.

Livingston Police Dep’t, 86 F.3d 469, 473 (5th Cir. 1996) (inferring that law

enforcement knew of risk from combination of potential trauma, complaints

of pain, and abrasions); see also Hare III, 135 F.3d at 322–23, 325 (determining

that law enforcement could infer suicide risk from threats of self-harm and

family’s concern).

Observing Williams’s behavior alone may not have been enough to

establish the defendants’ knowledge. We have granted qualified immunity

when law enforcement misconstrued the symptoms of a serious medical

condition for intoxication, see, e.g., Roberts v. Lessard, 841 F. App’x 691, 694

(5th Cir. 2021) (unpublished), or a less serious illness, Estate of Cheney v.

Collier, 560 F. App’x 271, 274–75 (5th Cir. 2014) (unpublished). But in those

cases, the officials had to assess the risk to the detainee’s health based on

symptoms alone. We afford law enforcement latitude in those situations

recognizing that they do not have the training of a medical professional. See

Burns v. City of Galveston, 905 F.2d 100, 104 (5th Cir. 1990).

Here, however, the officers’ knowledge of risk was based on much

more than just symptoms: They also knew that Williams had a life-

threatening condition and had suffered trauma of the type that would trigger

that condition. Those additional factors distinguish this case from the

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symptoms-only scenarios in Roberts and Cheney. Cf. Easter, 467 F.3d at 463–

64 (symptoms and diagnosis); Hegmann, 198 F.3d at 159–60 (same).

Considering all the facts together, a reasonable jury could find that Dean,

Banks, Harris, Jaco, and VanCleave all knew of a high risk that Williams was

bleeding internally.

Knowledge of risk, of course, is not enough for liability. Williams’s

survivors must also show that the officials failed to take reasonable measures

to abate that risk. See Farmer, 511 U.S. at 847. Again, they met their summary

judgment burden. We have repeatedly held that refusing to treat a detainee

and ignoring a detainee’s complaints are unreasonable responses to a known

medical risk. See, e.g., Perniciaro v. Lea, 901 F.3d 241, 258 (5th Cir. 2018)

(citing Johnson v. Treen, 759 F.2d 1236, 1238 (5th Cir. 1985)); see also Nerren,

86 F.3d at 473 (finding deliberate indifference because officers “turned a deaf

ear” to an inmate’s requests for medical attention). Yet that is exactly what

the defendants did. Despite knowing of Williams’s injury and condition, they

ignored his requests for help. In fact, they did not do anything to make sure

that he was okay. They did not question him about his medical condition,

move him to an observational cell, summon medical assistance, or even check

on him in the hours following his arrest. Ignoring Williams’s requests for

help and refusing to treat him were unreasonable responses to the known risk

to his life. See Easter, 467 F.3d at 465 (concluding that “offer[ing] no

treatment options to a patient with a history of cardiac problems who was

experiencing severe chest pains” was unreasonable).

The defendants believe that their response was reasonable because

Dean examined Williams’s abdomen prior to his arrest and Jaco called

Williams’s family to ask about his medical needs. The problem is that both

actions occurred before their conversation with Williams’s family. At that

point, only Dean and Banks knew that Williams had been hit with the pipe

and none of the defendants knew about his clotting disorder. They also had

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not yet observed him struggling to walk and passing out during booking.

Once they learned of the combination of Williams’s preexisting condition

and his trauma, they knew of the risk to his life and were obligated to take

reasonable action to abate that risk.

Langston also had knowledge of, yet ignored, the risk to Williams’s

life. The plaintiffs allege that she too heard Williams’s family tell the officers

about his clotting condition. But her involvement does not end there. On the

night Williams died, Langston was charged with checking on the detainees

hourly and providing them food and water. Williams’s fellow detainees say

that after he was brought to his cell in bad condition, they tried to get

Langston’s attention by beating on their cell doors for two to three hours and

repeatedly yelling things like “Help!” and “We have an emergency! We

need medical attention! We need a doctor!” A jury could find that Langston

heard these cries for help, in which case she certainly was aware of the risk

that Williams was experiencing a medical emergency. See Hegmann, 198 F.3d

at 159–60 (finding deliberate indifference because officials ignored “urgent

and repeated requests for immediate medical treatment”). Like the other

defendants, Langston did not do anything to make sure that Williams was

okay. According to the detainees, she did not investigate their concerns, call

for medical help, or even perform the hourly checks required by prison

policy. Instead, they allege, Langston’s only response to their cries was

telling them to stop beating on their doors. Such a total failure to act was

unreasonable. See Nerren, 86 F.3d at 473.

Defendants emphasize that deliberate indifference is not a “should

have known” standard; it requires actual knowledge of the serious medical

risk. But as we have chronicled, this is a case of direct knowledge. Numerous

sources—Williams, his family, and his fellow detainees—told law

enforcement that Williams needed medical attention for his life-threatening

blood clotting disorder. Their warnings fell on deaf ears. The defendants

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ignored their requests for help, leaving Williams to bleed to death in his cell.

If proven at trial, this indifference to Williams’s known, urgent medical needs

violated due process.

B

The defendants’ knowledge of Williams’s condition also means that

the unlawfulness of their conduct was clearly established. To defeat the

immunity defense, Williams’s survivors must show that his constitutional

rights were clearly established at the time of the violation. 6 al-Kidd, 563 U.S.

at 735. A right is clearly established if reasonable officials have notice that

their actions are unlawful. Morgan v. Swanson, 659 F.3d 359, 371–72 (5th Cir.

2011) (en banc). Caselaw must place the constitutional question “beyond

debate,” though it need not be “directly on point.” al-Kidd, 563 U.S. at 741.

Officers and jailers have long had notice that they cannot ignore a

detainee’s serious medical needs. It is clearly established that an official who

refuses to treat or ignores the complaints of a detainee violates their rights.

Sims v. Griffin, 35 F.4th 945, 951–52 (5th Cir. 2022) (citing Domino v. Tex.

Dep’t of Crim. Just., 239 F.3d 752, 756 (5th Cir. 2001)). We are mindful that

we must not define clearly established law “at too high a level of generality,”

City of Tahlequah v. Bond, 142 S. Ct. 9, 11 (2021), but we have seen cases like

this before.

6

The district court denied the defendants qualified immunity but did not address

whether the law was clearly established. But because the clearly established issue is a purely

legal question subject to our de novo review, we may address it now in the interest of judicial

economy rather than remanding. See Mitchell, 472 U.S. at 530 (finding immunity question

“appropriate for our immediate resolution” even though it was not addressed below

(quoting Nixon v. Fitzgerald, 457 U.S. 731, 743 n.23 (1982))). Addressing it now is the much

more efficient course in this long-pending case as any ruling by the district court on remand

would generate another appeal.

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We begin with Easter v. Powell, 467 F.3d 459 (5th Cir. 2006) (per

curiam). We denied qualified immunity to prison officials who knew that

Easter had a preexisting, serious heart problem but refused him treatment

when he presented with severe chest pain. Easter, 467 F.3d at 463-64. The

same elements exist here: The defendants knew that Williams had a life-

threatening preexisting condition and that his condition was potentially

triggered, yet they “turned a deaf ear to his request for medical treatment.”

See id. at 464. Easter thus establishes these defendants’ deliberate

indifference to Williams’s known condition.

Nerren v. Livingston Police Department, 86 F.3d 469 (5th Cir. 1996), is

similar. There, we denied qualified immunity to officers who rejected

Nerren’s request for medical assistance despite knowing that he was involved

in a car accident. Nerren, 86 F.3d at 470-71. The reasons for our decision are

familiar. Again, we noted the officers’ knowledge of a potentially harmful

circumstance and their “deaf ear” to the detainee’s request for care. Id. at

473. Contrast Williams v. Zachary, No. 21-60753, 2022 WL 2101518, at *4

(5th Cir. June 10, 2022) (distinguishing Nerren because officers did not know

that detainee “had recently undergone significant trauma” and detainee did

not ask the officers for medical care).

The facts of this case fit comfortably within Easter’s and Nerren’s

teaching that law enforcement may not ignore reports that a detainee is

suffering a serious medical emergency, particularly when those reports are

backed by knowledge of a preexisting condition or trauma. Here, the reports

came from numerous sources: Williams, his family, and his fellow detainees.

At the time of Williams’s death, it was beyond debate that the defendants’

total failure to respond to his medical needs was unconstitutional.

We do not know whether a jury will agree with Williams’s survivors’

and fellow detainees’ account of what happened the night of his death. But

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if they do, the defendants violated clearly established law by responding to

Williams’s serious medical need with deliberate indifference. The district

court correctly held that the federal denial-of-care claim can proceed to trial.

***

We DISMISS Yazoo City’s appeals for lack of jurisdiction,

AFFIRM the district court’s denial of qualified immunity to the individual

defendants on the federal denial-of-medical-care claim, and REMAND for

further proceedings.

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