A federal appellate court has affirmed qualified immunity for three officers after a man died while in custody in Texarkana. The officers had mistaken his rare medical condition for extreme exhaustion after running from campus police for half a mile.
The decision confirmed the high standards for officers to be held personally liable for actions they take in the course of their duties, particularly when they have not violated a clearly established law.
Background
On a hot summer day in 2019, Texarkana College police officers confronted Darren Cornelius Boykin, who they suspected of multiple thefts on campus. He was not enrolled as a student.
Boykin fled on foot, running for about half a mile in the heat before being caught. Despite resisting, he was ultimately subdued before several officers from the Texarkana Police Department arrived on scene.
At the time of his arrest, it was discovered that Boykin had a parole violation warrant out of Ohio for burglary.
Boykin had difficulty walking to the patrol car and needed to be carried. Once in the vehicle, he complained of being unable to breathe. Officers believed these symptoms were attributable to extreme exercise and turned up the air conditioning.
Over the ten minute drive to the jail, Boykin said he was “about to pass out,” and subsequently lost consciousness. Officer Jerrika Weaver—who was driving the vehicle—offered to find him water upon arrival.
By the time Weaver opened the rear door, Boykin was unresponsive and without a pulse. She immediately began resuscitation efforts and called for emergency medical assistance. Paramedics restored Boykin’s pulse but he ultimately died at the hospital.
Unbeknownst to the officers, Boykin had a rare condition—sickle cell trait—that made him particularly vulnerable to sudden death from extreme exertion. This flared up when he ran from the police for a half-mile and was mistaken for extreme exhaustion.
Following his death, Boykin’s family filed a federal lawsuit in the U.S. District Court for the Eastern District of Texas, alleging that the officers were deliberately indifferent to Boykin’s serious medical needs, a Fourteenth Amendment claim under the U.S. Constitution.
Named as defendants in the suit were three officers—Brent Hobbs, William Scott, and Weaver.
The district court ruled in favor of the officers, granting each of them qualified immunity. The family immediately appealed this decision to the U.S. Fifth Circuit Court of Appeals in New Orleans.
The Appeal
Qualified immunity is the legal doctrine that shields government officials, including police officers, from being held personally liable for civil damages. To overcome qualified immunity, plaintiffs must prove that the officer violated a clearly established statutory or constitutional right.
Last week, the Fifth Circuit released its decision, affirming the lower court ruling and upholding each of the officers’ claims of qualified immunity.
First, the court found that “[n]o reasonable jury could find that Hobbs or Scott actually knew of Boykin’s medical needs at the arrest scene.” Both Hobbs and Scott only interacted with Boykin while he was still talking and complaining of conditions that appeared to be exhaustion from the extreme exercise he endured while fleeing.
In regard to Officer Weaver, the court concluded that a reasonable jury “could find” that she discovered Boykin’s medical needs during the drive—but even this was not certain.
“While Weaver’s demeanor suggests that she was unaware of Boykin’s condition, other evidence suggests that she was,” Judge James Graves Jr. wrote. “This conflicting evidence creates a genuine dispute whether Weaver was deliberately indifferent.”
Even if Weaver did discover Boykin’s medical needs, plaintiffs could not prove that Weaver would have violated a clearly established law by not administering treatment and seeking emergency services in the time that she did.
“Simply put, plaintiffs offer no case that clearly established, in 2019, that an officer who observes a serious threat to a detainee’s life during transport to jail must immediately secure aid,” reads the ruling. “So they fail to overcome qualified immunity, and Weaver enjoys the immunity as a matter of law.”
It was not until 2021 that the Fifth Circuit had established that failing to promptly call for emergency assistance in response to a serious threat to an inmate’s life constituted deliberate indifference.
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