Villegas v. Metropolitan Government of Nashville

Juana Villegas (plaintiff) was nine months pregnant when she was brought to jail by police officers working in the Metropolitan Government of Nashville (defendant). While Villegas was at the jail, officers discovered that she did not have lawful immigration status, and a detainer was placed on her. Because of Villegas’s detainer status, she was automatically deemed a medium-security inmate. After Villegas spent two days in jail, she began to go into labor. Two officers put Villegas on a stretcher, restrained her extremities with shackles, and transported her to the nearby hospital. Villegas was admitted to the hospital and remained in shackles. When it was time for the shift change, a new officer reported to the hospital and was informed of Villegas’s medium-security status. The officer removed all but one of the restraints. At some point during the shift, the officer overheard the doctor discussing a no-restraint order, and a nurse told the officer that Villegas should not be restrained during labor. The doctor put a no-restraint order in Villegas’s file but did not inform the officer. At 11:00 p.m., another shift change took place. The new officer was told by the released officer to prepare for a no-restraint order. The third officer then removed all restraints. Two hours later, Villegas gave birth. Villegas remained unrestrained until 7:00 am, at which time an officer restrained her ankle. Villegas filed suit under 42 U.S.C. § 1983, alleging that her right to be free from cruel and unusual punishment under the Eighth Amendment to the United States Constitution had been violated because the officers showed deliberate indifference to her needs. The district court granted summary judgment to Villegas. The government appealed.