Johnson & Bell Municipality Attorney, Samuel D. Branum, obtained summary judgment in favor of his clients – a municipality and a sheriff – in a dispute over a policy plaintiff claimed defendants used to refuse dental care in violation of his Fourteenth Amendment rights. This outcome is important as it is a reminder that under the Fourteenth Amendment, detainees are entitled to objectively reasonable care, not the specific care they want.
In this case, plaintiff suffered from a chronic toothache while detained at a jail and claimed he should have received a root canal to address the issue. Plaintiff was seen by multiple dentists who offered to extract the problematic tooth, but he refused treatment, claiming that a dentist told him the tooth could be salvaged with a root canal. Plaintiff alleged that defendants violated his constitutional rights by withholding care in the form of a root canal. Defense argued that plaintiff’s constitutional rights were not violated because he was offered objectively reasonable treatment – an extraction – for his extensively decayed tooth. Plaintiff responded that a root canal was a viable treatment option, but he failed to present evidence that an extraction was objectively unreasonable in his case. The court pointed out that the flaw in plaintiff’s argument was his focus on the appropriateness of root canal treatment rather than submitting evidence that the offered treatment was unreasonable. In granting summary judgment to defendants, the court explained that the Fourteenth Amendment “requires that [a detained person] received reasonable care, not specific care….”