No Dismissal for San Diego Jail Medical Contractor from Suit Filed Over Detainee’s Withdrawal Death
On February 8, 2024, the U.S. District Court of the Southern District of California declined to dismiss all the claims brought by the family of a San Diego Jail detainee who died in custody of drug withdrawal while under the care of the lockup’s contracted medical provider, Correctional Healthcare Partners (CHP).
In the early morning hours of March 10, 2022, William Hayden Schuck, 22, was arrested for DUI after he wrecked his car in Ocean Beach and responding cops found drugs inside. At booking into San Diego Central Jail, an intake nurse noted that Schuck was incoherent and making nonsensical statements. Schuck stated that he had been awake for the past 44 hours. Although 6’2” tall, he weighed only 131 pounds.
Jail guards transported Schuck to a local hospital for an evaluation, where he refused treatment. Hospital staff gave guards medical records indicating that he needed follow up care because he had a family history of ischemic heart disease, a condition which can cause arrythmia and heart failure. But CHP medical staff at the jail did not review these records or provide follow up care. Nor did they test him for drugs or recommend that he be placed in an observation bed for stabilization.
Instead Schuck was placed in solitary confinement after returning from the hospital, and he received no further medical care even though he was unable to attend court on March 14, 2022. The following day, CHP staff evaluating Schuck noted that he was covered in bedsores, had elevated vital signs and altered thought processes. To them, Schuck appeared “disheveled, with soiled t-shirt,” was “not wearing pants,” and had “dry blood” on his t-shirt and “both lower extremities,” the Court recalled. An hour later, a nurse observed a non-responsive Schuck lying naked on his bed facing the wall with pressure ulcers (bed sores) covering his body. Despite these obvious signs of distress, CHP staff did not enter the cell or provide any medical care.
Later that day, jail guards transported Schuck to court for arraignment, where he could not confirm his name, and his public defender expressed concern for his ability to comprehend court proceedings. The judge discontinued the arraignment and ordered the jail to provide medical care for Schuck. While being escorted back to his holding cell, Schuck fell multiple times and had to be assisted by guards. CHP staff then received a copy of the court’s order requiring that Schuck be medically evaluated, but no one complied with the directive.
The next morning, March 16, 2024, Schuck did not eat the breakfast guards left for him. When they entered his cell several hours later, he was found unresponsive with no pulse. The medical examiner determined that Schuck “died from profound dehydration” and “untreated withdrawals, which ultimately caused heart failure.” Schuck’s parents sued several jail guards and CHP staff, alleging they violated his constitutional rights by allowing him to die of an entirely preventable condition after clear signs that he required medical intervention.
The CHP defendants moved to dismiss the complaint pursuant to Fed. R. Civ. P. 12(b)(6), arguing that Schuck’s complaint failed to sufficiently allege a cause of action against them. The Court rejected most of CHP’s arguments, holding that Schuck sufficiently alleged a deliberate indifference claim against several CHP medical providers because the evidence showed they knew of Schuck’s serious medical needs but failed to intervene to treat them. The Court found Schuck’s factual allegations wanting, though, as they related to several supervisory CHP staffers; they were dismissed from the case subject to Plaintiffs’ filing an amended complaint to correct the deficiency.
The Court also refused to dismiss Schuck’s claims against CHP for its employees’ failures, as provided in Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (1978). The Court found the complaint sufficiently alleged that the company violated his constitutional rights by failing to properly train its employees and by maintaining policies or customs that contributed to constitutionally inadequate medical care. Many of Schuck’s state law claims were permitted to proceed as well. The Schuck family is represented by attorneys Lauren M. Williams and Timothy A. Scott of McKenzie Scott, PC in San Diego. See: Est. of Schuck v. Cty. of San Diego, 2024 U.S. Dist. LEXIS 22653 (S.D. Cal.).
In a separate proceeding before the San Diego County Citizens’ Law Enforcement Review Board, members concluded that the jail failed to properly report Schuck’s death and also failed to prevent narcotics from entering the facility—drugs that Schuck somehow consumed, contributing to his death. Scott disputed that, insisting that “any drugs in Hayden’s system, and there were some, were used pre-custody.”
Additional source: KGTV
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