Case Explained: Jessica Ann McKee v. Jessica J. Brady, in her individual as well as her official capacity as a nurse at the Steele County Detention Center Defendant – Appellant Steele County

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-08-17 The Eighth Circuit reversed the district court’s denial of summary judgment and granted qualified immunity to Nurse Jessica J. Brady. The court held that the plaintiff, a pretrial detainee, failed to demonstrate that it was clearly established that Brady’s conduct constituted deliberate indifference to her serious medical needs in violation of the Fourteenth Amendment’s Due Process Clause. The court applied the standard that government officials are entitled to qualified immunity unless they violate clearly established statutory or constitutional rights of which a reasonable person would have known. To overcome this defense, the plaintiff must show that the official violated a clearly established right by acting with deliberate indifference, defined as a mental state akin to criminal recklessness, rather than mere negligence. The court found that Brady responded to all of McKee’s requests, authorized diet changes, reasonably denied bunk requests due to lack of documentation, and forwarded prescription records to a physician when her own license did not authorize prescribing medication. The court concluded that while Brady may have been negligent in relying on the detainee’s self-assessment or failing to act more aggressively, negligence is insufficient to establish deliberate indifference, and there was no clearly established right requiring a nurse to monitor a physician’s treatment decisions or prescribe medication outside her scope of authority. As a result of this ruling, the case against Nurse Brady is dismissed at the summary judgment stage, and she is shielded from further liability for the alleged constitutional violations. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.