Court Grants Summary Judgement in Favor of Jail Staff Concerning Inmate’s Diabetic Care

November 8, 2016

Summary judgment was granted in favor of correctional officers, jail administrative staff, and the jail medical staff  in Harris  v. Senesac, et al., No. 15-cv-02067-SLD. The jail inmate, Spencer Harris, alleged that the jail staff acted deliberately indifferent towards his Type-2 Diabetes. The inmate also claimed that his conditions of confinement were constitutionally inadequate. Specifically, Harris alleged that the jail did not provide an adequate diabetic menu or adequate medical treatment for diabetic inmates. He also claimed that he suffered a hyperglycemic episode after being booked into the detention facility because the room was too cold.

The court found that the jail staff provided Harris with adequate medical care and noted that Harris’ diabetic condition actually improved during his stay in the detention facility. The court further found the jail staff was allowed to rely on a third-party dietitian to provide an appropriate diabetic diet for Harris, as prescribed by the medical staff. Moreover, in a subsequent order, the court concluded that the corrections staff acted appropriately at Harris’ intake by informing a nurse of Harris’ condition and blood sugar levels in a timely manner and therefore could not be held liable for his hyperglycemic episode soon after intake. The court further found that the medical staff did not have sufficient interaction with the inmate prior to his hyperglycemic episode at intake to be held liable for deliberate indifference.

Michael Condon and Tony Fioretti represented the defendants.

Harris v Senesac

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