Prisons: Danville law enforcement officials sued after inmate’s death

Where an individual suffering from acute alcohol withdrawal syndrome died a few hours after being booked into the Danville City Jail, the deliberate indifference claim brought by his estate survived the motion to dismiss. The amended complaint alleged facts making it plausible the decedent was suffering from a serious medical need and that defendants were deliberately indifferent to it.

Background

Anthony Wyatt was arrested for public intoxication. Apparently not intoxicated but suffering from acute alcohol withdrawal syndrome, Wyatt passed out in his cell shortly after being booked into the Danville City Jail. He died just a few hours later.

The administrator of Anthony Wyatt’s estate sued Mike Mondul (Sheriff of the City of Danville), J.K. Reynolds (the arresting officer) and Robert Skrocki (the intake officer who processed Wyatt into the jail). Mondul and Reynolds filed motions to dismiss.

Unreasonable seizure

            Reynolds contends that plaintiff fails to state a claim for unreasonable seizure under the Fourth Amendment because, taking the facts of the complaint as true, a reasonable officer would have believed that probable cause existed to arrest Wyatt for public intoxication. The court agrees. On the facts alleged in the amended complaint, a reasonable officer would certainly have a sufficient basis to conclude that there was probable cause that Wyatt was intoxicated, and therefore his subsequent arrest, under plaintiff’s allegation of the facts, was not unreasonable.

Plaintiff attempts to avoid this conclusion by alleging that Wyatt’s fiancée told Reynolds that Wyatt was sober and had not imbibed in four days. This fact does nothing to negate the ample probable cause facing Reynolds, nor does it account for the possibility of intoxication from “narcotic drug, or other intoxicant or drug of whatever nature. . .”. Moreover, even if it was true that Wyatt was sober, the facts that day—as plaintiff alleges them—would nevertheless lead a reasonable officer to believe that Wyatt was intoxicated.

Alternatively, if the facts did not establish probable cause to arrest Wyatt for public intoxication, the magistrate’s issuance of an arrest warrant for that crime, as alleged in the complaint, serves to insulate Reynolds from liability.

Deliberate indifference

Reynolds contends that plaintiff’s amended complaint fails to allege that Wyatt was suffering from a serious medical need or that he was deliberately indifferent to it. The court disagrees.

            Plaintiff alleges that, upon arrival at the jail, “Wyatt could not . . . extricate himself from the police vehicle” and “could not walk and needed to be transported into the jail by wheelchair.” At booking and during his medical screening, Wyatt was “unable to answer . . . questions” posed to him by Skrocki. These facts, taken as true, would establish that Wyatt was suffering from a serious medical condition at the time he arrived at the jail and both Reynolds, as the arresting officer, would have been aware of his condition.

If Wyatt was suffering from some acute intoxication (either drugs or alcohol), then his worsening state while in Reynolds’s custody indicated a need for medical care above and beyond the run-of-the-mill drug or alcohol user police officers typically encounter. And if Wyatt was not intoxicated—as alleged in the complaint and buttressed by his subsequent diagnosis of alcohol withdrawal syndrome and the fact that Wyatt is alleged not to have smelled of alcohol—then his worsening condition and increasingly alarming symptoms cried out even more loudly for medical intervention.

In the face of these facts, it would be “objectively unreasonable” to fail to secure medical attention for Wyatt. Accordingly, plaintiff has stated a claim for deliberate indifference to a serious medical need.

Policy

            Mondul contends that, because plaintiff’s claim is one alleging that, as sheriff, he implemented an unconstitutional policy or procedure, such a claim is actionable only against the municipality and therefore against him only in his official capacity. But because he cannot be sued in his official capacity, plaintiff’s effort to shoehorn his complaint into a personal-capacity suit is misplaced. Plaintiff counters that, as recognized in Gordon v. Schilling, 937 F.3d 348 (4th Cir. 2019), an individual can be held responsible for the implementation of an unconstitutional policy in certain circumstances.

Plaintiff has the better argument. Like the plaintiff in Gordon, plaintiff alleges that Mondul instituted a policy whose future constitutional harm was imminently foreseeable. Such a policy, if instated, is certainly of the type found in Gordon to require submission of the facts to a jury and is sufficient to state a claim at this early stage.

Defendants’ motions to dismiss granted in part, denied in part.

Wyatt v. Mondul, Case No. 4:24-cv-00049, July 21, 2025. WDVA at Danville (Cullen). VLW 025-3-299. 18 pp.