Philomene Long, Surviving Spouse and Heir-At-Law of John Thomas Idlet, Deceased v. County of Los Angeles

John Thomas Idlet, the decedent, reported to the Los Angeles County Jail on March 11, 2002, to begin a 120-day jail sentence. Mr. Idlet was seventy-one years old and suffered from congestive heart failure and other ailments. Over the next eighteen days Mr. Idlet’s medical condition deteriorated. Although nurses saw him several times during that period, there is no record of a doctor’s examination until the early morning of March 29, 2002, hours before he died of cardiac arrest.

Mr. Idlet’s wife, the Plaintiff and Appellant in this action, filed a complaint, based on 42 U.S.C. § 1983 . The district court dismissed all of the claims against all of the defendants except the County, against whom Appellant asserted municipal liability for failing adequately to train jail medical staff and failing to implement necessary medical policies, leading to the denial of adequate medical care which resulted in Mr. Idlet’s death. The County moved for summary judgment.

The district court granted the County’s motion and found that, while a triable issue of fact existed as to whether jail medical staff had deprived Mr. Idlet of constitutionally adequate medical care, summary judgment as to the…