Congious v. Shaw: Medical Deliberate Indifference and Qualified Immunity

This episode from the Fifth Circuit Court of Appeals details a lawsuit involving a pretrial detainee who gave birth alone in her jail cell, resulting in the subsequent death of her infant. The plaintiff alleged that the facility's medical director violated the Fourteenth Amendment by failing to provide adequate care despite knowing the risks of her pregnancy. The court ultimately affirmed a summary judgment in favor of the doctor, ruling that he lacked the subjective knowledge of immediate danger required to prove a constitutional violation. While a concurring judge argued that the risks were obvious enough to imply knowledge, they agreed the doctor was protected by qualified immunity because no clearly established law was violated. Consequently, the court found the medical director could not be held personally liable for the tragic outcome of the unattended birth.