Editor’s Note: Law Week Colorado edits court opinion summaries for style and, when necessary, length.
Alexander Garcia, a pretrial detainee in the Adams County Detention Facility, has sleep apnea. This disorder causes him to stop breathing 103 times per hour, wake up choking and coughing, as well as pain, daily migraines and mild blackouts. He was diagnosed in 2017 and prescribed a CPAP machine.
Garcia entered the detention facility in 2021 and used a CPAP machine during a previous term of incarceration at the Adams County Detention Facility. Although he was approved to use the CPAP machine, the facility didn’t provide one and Garcia didn’t have his own, which was lost.
Medical staff at the facility prescribed oxygen and pain relievers for headaches and gave Garcia an oxygen concentrator, yet his symptoms persisted.
Based on these allegations, Garcia filed a complaint alleging deliberate indifference to a serious medical need, a claim available to pretrial detainees under the 14th Amendment.
A Colorado district court dismissed the complaint.
The 10th Circuit Court of Appeals affirmed the lower court’s position and decided that Garcia failed to state a claim.