In a recent ruling, a federal appeals court sided with Florida correctional officers in a lawsuit regarding the 2017 death of inmate Jose Gregory Villegas at Lake Correctional Institution.
The 11th U.S. Circuit Court of Appeals, in a 2-1 decision, upheld the district court’s granting of summary judgment to the officers, ruling that they were entitled to qualified immunity because their conduct did not violate any clearly established right.
Villegas, who had been restrained by multiple officers after becoming combative, was found unresponsive in his cell.
The opinion noted that he had ingested the synthetic drug K2. After being placed in a wheelchair and wheeled to another prison dorm, Villegas’s condition worsened, and medical staff later determined he had no pulse. He was pronounced dead after unsuccessful resuscitation efforts.
An autopsy attributed his death to cardiac arrest, exacerbated by physical strain and excited delirium.
The court majority, led by Judge Barbara Lagoa and joined by Judge Ed Carnes, found that the officers did not violate clearly established law, thus qualifying for immunity.
However, Judge Adalberto Jordan dissented, arguing that the officers failed to take reasonable steps in addressing Villegas’s medical condition and should not have been entitled to immunity.