Larry Richardson v. Nathan Falk

Summary

The Sixth Circuit reversed the district court's denial of qualified immunity to a corrections officer who, after an inmate orally complained of chest pain and asked to go to healthcare, ordered him back to his cell; the inmate was taken to the medical wing eight minutes later and suffered a heart attack about an hour after arriving. Accepting the inmate's version of the facts, the court held that no on-point controlling authority or robust consensus of persuasive authority put the officer on notice that failing to immediately respond to a bare oral complaint of chest pain, without external signs of distress, violates the Eighth Amendment. The right had to be defined through the officer's particular circumstances—what he knew and saw, the severity and immediacy of the need, and his response—and precedents turning on visible symptoms, cumulative 'classic' signs, or much longer delays did not clearly establish a duty of immediate response. The court remanded for entry of judgment in favor of the officer.