ELECTRONICALLY FILED - 2017 Jun 14 11:31 AM - HORRY - COMMON PLEAS - CASE#2017CP2603706

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

)
COUNTY OF HORRY ) C/A NO.: 2017-CP-26-_____
)
Titus Leroy Walker, individually and as Personal )
Representative of the Estate of Jerome Floyd, )
)
Plaintiff, ) SUMMONS
)
vs. )
)
City of Myrtle Beach, Myrtle Beach Police )
Department, Horry County Sheriffs Office, Horry )
County Detention Center, Southern Health )
Partners, Inc., and Charles A. Bush, MD, )

Defendants.
TO THE DEFENDANTS ABOVE-NAMED:

YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy of
which is hereby served upon you, and to serve a copy of your Answer to this Complaint upon the
subscriber at the address shown below, within thirty (30) days after service hereof, exclusive of the day
of such service, and if you fail to Answer the Complaint, judgment by default will be rendered against
you for the relief demanded in the Complaint.

__s/C. Carter Elliott, Jr.________

C. Carter Elliott, Jr., Esq.
Elliott & Phelan, LLC
117 Screven Street
P.O. Box 1405
Georgetown, SC 29442
(843) 546-0650
(843) 546-1920 (fax)
June 14, 2017
Georgetown, South Carolina ATTORNEY FOR THE PLAINTIFFS
 ELECTRONICALLY FILED - 2017 Jun 14 11:31 AM - HORRY - COMMON PLEAS - CASE#2017CP2603706
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) FIFTHTEENTH JUDICIAL CIRCUIT
COUNTY OF HORRY )
) CASE NO.:
Titus Leroy Walker, individually and )
as Personal Representative of the )
Estate of Jerome Floyd, )
) COMPLAINT
Plaintiff, )
) Jury Trial Requested
vs. )
)
City of Myrtle Beach, Myrtle Beach )
Police Department, Horry County )
Sheriffs Office, Horry County )
Detention Center, Southern Health )
Partners, Inc., and Charles A. Bush,
MD,

Defendants.

The Plaintiff, Titus Leroy Walker, individually and as Personal

Representative of the Estate of Jerome Floyd, complaining of the Defendants -

would respectfully show unto this Honorable Court:

PARTIES, JURISDICTION, AND VENUE

1. The Plaintiff, Titus Leroy Walker, is a citizen and resident of the

County of Horry, State of South Carolina. As the natural father of the decedent

and grandfather of the only heir, he is the properly appointed Personal

Representative of the Estate of Jerome Floyd by Order of the Horry County

Probate Court dated August 28, 2015 under case number 2015-ES-26-01806.

2. The Defendant, City of Myrtle Beach, is a political subdivision of

the State of South Carolina as defined in Section 15-78-10 et seq. of the Code

of Laws of South Carolina (1985), as amended. At all times hereinafter

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mentioned in this complaint, this Defendant owned and/or operated the Myrtle

Beach Police Department, and it acted or carried on its business by and

through its agents, servants, and/or employees. Additionally, during the time

period set out in the complaint, these employees were operating within the

scope of their officially assigned and/or compensated duties.

3. The Defendant, Myrtle Beach Police Department (hereinafter

referred to as MBPD), is a governmental agency and/or political subdivision

of the State of South Carolina, existing under the laws of the State of South

Carolina (as defined by Section 15-78-10 et seq. of the Code of Laws of South

Carolina (1985), as amended) and has facilities located in the County of Horry,

South Carolina. At all times hereinafter mentioned in this Complaint, this

Defendant owned and/or operated its own Detention Section and acted and

carried on its business by and through its agents, servants, and/or employees.

Additionally, during the time period set out in the Complaint, these employees

were operating within the scope of their officially assigned and/or compensated

duties.

4. The Defendant, Horry County Sheriffs Department (hereinafter

referred to as Sheriffs Department), is a governmental agency and/or political

subdivision of the State of South Carolina, existing under the laws of the State

of South Carolina (as defined by Section 15-78-10 et seq. of the Code of Laws of

South Carolina (1985), as amended) and has facilities located in the County of

Horry, South Carolina. At all times hereinafter mentioned in this Complaint,

this Defendant owned and/or operated the Horry County Detention Center and

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acted and carried on its business by and through its agents, servants, and/or

employees. Additionally, during the time period set out in the Complaint, these

employees were operating within the scope of their officially assigned and/or

compensated duties.

5. The Defendant, Horry County Detention Center (hereinafter

referred to as Detention Center), is a political subdivision of the State of

South Carolina as defined in Section 15-78-10 et seq. of the Code of Laws of

South Carolina (1985), as amended. At all times hereinafter mentioned in the

Complaint, this Defendant owned and/or operated the Detention Center,

located in Horry County, South Carolina, and carried on its business by and

through its agents, servants, and/or employees. Additionally, during the time

period set out in the Complaint, these employees were acting within the scope

of their officially assigned and/or compensated duties.

6. The Defendant, Southern Health Partners, Inc. (hereinafter known

as SHP), is a corporation authorized to do business in South Carolina and at

all times mentioned in this Complaint, had a contractual relationship with the

Horry County Detention Center and/or Horry County Sheriffs Office, to provide

medical care and services to detainees/inmates located at and in the custody of

the Detention Center. During the time period set out in the complaint, this

Defendant acted and carried on its business by and through its agents,

servants, and/or employees at the Horry County Detention Center to include

the nursing staff and Dr. Bush. Additionally, at all times mentioned herein, a

doctor/patient relationship existed between the Defendant and the Decedent.

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7. Upon information and belief, the Defendant, Charles A. Bush,

M.D., is a citizen and resident of the County of Beaufort, State of South

Carolina (hereinafter Bush). At all times mentioned in this lawsuit, the

Defendant Bush was acting individually, as an independent contractor, or as a

servant, agent and/or employee of Southern Health Partners, Inc., Horry

County Detention Center, and/or the Horry County Sheriffs Office.

Additionally, at all times mentioned in the Complaint, Dr. Bush was acting as

the responsible physician with regard to the medical care being administered to

the detainees at the Horry County Detention Center. At all times mentioned in

the Complaint, Dr. Bush had a doctor-patient relationship with the Decedent.

8. The Plaintiff is informed and believes that, at present, it has not

been established whether the pre-litigation filing requirements of the Medical

Malpractice Reform Act of 2005 are applicable to cases involving governmental

entities or charitable institutions (section 18 of the Act creates an issue as to

the act under these circumstances). However, since the incident giving rise to

this cause of action occurred after the effective date of the Act, the Plaintiff

herein is both filing this Summons and Complaint against the Defendant, while

also complying with the pre-lawsuit procedural requirements provided for by

the Act, including those provided for in sections 15-79-120, 15-70-100, and

15-36-100 of the South Carolina Code of Laws. Should the Defendant concede

or stipulate (or should it be determined) that the pre-lawsuit procedural

requirements are applicable to the causes of action alleged in this case, the

Plaintiff agrees or concedes that the case should continue pursuant to the

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Notice of Intent and the applicable provisions of the Medical Malpractice

Reform Act of 2005. Additionally, if the Defendant concedes that the Medical

Malpractice Reform Act of 2005 does not apply to governmental entities, then

the Plaintiff will agree to dismiss its Notice of Intent to Sue (filed

simultaneously herewith) and proceed with this action under the above-

mentioned Complaint.

9. Additionally, in order to comply with all statutory requirements

Plaintiff is attaching and incorporating by reference the affidavit from the

following medical expert: Jay B. Krasner, MD.

10. Plaintiff is informed and believes that venue is proper in Horry

County as a substantial portion of the actions and/or occurrences took place

in Horry County.

FACTS

11. Jerome Floyd was arrested by MBPD officers on or about August

18, 2015 at approximately 8:40pm. Incident reports filled out by MBPD officers

indicate that the decedent was found stumbling through a parking lot smelling

strongly of alcohol. Plaintiff is informed and believes that at this time MBPD

officers knew or should have known that the decedent required immediate

medical clearance before taking him to a detention facility for placement.

Failure to have someone in the decedents condition medically cleared prior to

incarceration is a gross deviation from the appropriate standard of care.

12. At approximately 8:48pm, MBPD officers began the process of

booking the decedent into their Detention Section located at MBPD

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headquarters in the Ted. C. Collins Law Enforcement Center on North Oak

Street in Myrtle Beach, SC. A medical screening history form filled out by

MBPD officers document that the decedent had a history of type 2 diabetes,

epilepsy, and high blood pressure and that he was currently under a

physicians care for HIV and his diabetes. This form further documents that the

decedent was intoxicated and smelled heavily of alcohol; however, no plan is

made to get the decedent evaluated and/or treated by any medical professional

and/or placed into observation for possible detox. At this time the failure of

the Defendant MBPD (by ad through their employees) to transport the decedent

to the closest medical facility was a gross breach in the appropriate standard of

professional conduct.

13. Instead the decedent was transported and booked into the Horry

County Detention Center on or about August 19, 2015 at approximately

11:30am. The Plaintiff is informed and believes that the decedent had been

detained at this facility on several prior occasions. Further, the Defendants

were well aware of his numerous illnesses and conditions. During the intake

process it was determined by the detention and medical staff that the decedent

suffered from and/or had a medical history of diabetes and high blood pressure

both of which he took medications for. The initial booking medical screening

goes on to indicate that the decedent appeared dazed; however, there is no

indication that Mr. Floyd was placed under observation and/or immediately

seen by medical. Failure to ensure that the decedent was seen by medical staff

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or to send the decedent immediately to the closest hospital was a gross breach

in the appropriate standard of care and conduct.

14. At approximately 5:03pm, the decedent was seen by medical staff

as a follow-up to the intake medical screening. Mr. Floyd is again noted as a

diabetic with high blood pressure and orders are begun to continue the

decedents medications that were brought in with him. Vitals taken at this time

show that Mr. Floyds blood sugar level was over 300 and he had a BP reading

of 144/84. It was recommended by medical staff that the decedent needed an

immediate emergency medical referral and should be placed in the infirmary so

that his blood sugar and blood pressure levels could be closely monitored;

however, this was ignored by security staff. During this time, the decedent was

never seen or examined by a physician. The failure of the jail and nursing staff

to communicate with a physician was a gross deviation in the acceptable

standard of care. If there was no physician on call then it was a gross deviation

from the acceptable standard of medical care not to have the decedent

immediately sent to the closest hospital.

15. At approximately 7:17pm, the decedent was classified and placed

into B3-Pod (Special Needs unit) cell B111. Plaintiff is informed and believes

that this unit was set up to house those detainees that suffered from chronic

illnesses and who would need to be followed closer by medical; however, when

medical personnel came to the unit they did not see the decedent. On several

occasions there is an indication that the decedent refused care. This is yet

another reason to have the decedent sent to the nearest hospital. Failure to

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closely monitor someone in the decedents condition is a gross deviation from

the appropriate standard of care.

16. Records indicate that the decedent received no medical care after

his placement into the B3-Pod this would include and not be limited to

receiving medication and/or his blood sugar and pressure checks. Specifically,

the decedents blood sugar and blood pressure levels were not checked at

5:00am August 20, 2015 or at 2:30pm August 20, 2015; nor did he receive his

prescribed insulin at 6:00am on August 20, 2015. Again, the failure of the jail

and medical staff to ensure that the decedent was seen and treated by a

physician was a gross deviation from the acceptable standard of medical care.

17. On or about August 20, 2015 at approximately 3:51pm, Mr. Floyd

was found in his cell appearing to not be breathing. A code black was called

and all first responders and medical staff were dispatched to the decedents

cell. CPR was immediately started and EMS was called who transported Mr.

Floyd to Conway Medical Center at approximately 4:23pm where he was

pronounced dead at approximately 5:01pm.

18. An autopsy was held on August 21, 2015 at which time it was

determined that Mr. Floyd died from arteriosclerotic cardiovascular disease.

19. The Plaintiff is informed and believes that it is more likely than not

that the above actions and/or inactions by the Defendants caused the decedent

to needlessly suffer which led directly and contributed to his untimely death.

Based on the decedents medical history of diabetes, hypertension, and HIV, as

well as the fact that he was extremely intoxicated on arrest in addition to his

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uncontrolled blood sugars this likely put more stress on the decedents vital

organs (and in particular, his heart), which more likely than not contributed to

his ultimate death. Additionally, it is more likely than not that had the Plaintiff

been properly diagnosed, assessed and monitored by the jail and medical staff

at the Detention Center his death would have been prevented. Specifically,

had the jail and/or medical staff sent the decedent to the closest hospital

and/or had him examined by a physician, they would have likely seen (through

proper examination and history) that he required immediate treatment

FOR A FIRST CAUSE OF ACTION AGAINST THE DEFENDANTS

(Gross Negligence - Survival)

20. The Plaintiff reiterates each and every allegation stated above as if

repeated verbatim herein.

21. The Defendants were acting under the color or pretense of State

law, customs, practices, usage or policy at all times mentioned herein as

correctional officers, medical personnel, supervisors or other such personnel

and/or employees and had certain duties imposed upon them with regard to

the Decedent.

22. The above set forth incidents which resulted in the conscious

suffering of the Decedent (both mentally and physically) were proximately

caused by the negligent, grossly negligent, reckless, willful and wanton acts of

the Defendant in the following particulars:

AS TO THE DEFENDANTS CITY OF MYRTLE BEACH, MYRTLE BEACH

POLICE DEPARTMENT, HORRY COUNTY SHERIFFS OFFICE AND HORRY
COUNTY DETENTION CENTER
(Gross Negligence Survival)

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a) In failing to properly care for the Decedent, when the Defendants and/or
their personnel, agents, and/or employees knew or should have known
that the Decedent was in dire need medical assistance and/or treatment;

b) In failing to provide the appropriate, reasonable and necessary medical

care, and medications;

c) In failing to ensure that the Decedent was seen by a physician;

d) In failing to properly oversee and monitor the Decedents medical care to

include his uncontrolled diabetes, hypertension and HIV;

e) In disregarding the Decedents uncontrolled diabetes, hypertension and

HIV and failing to discuss a treatment plan with a physician;

f) In failing to discuss the Decedents mental health with a physician and

implementing an evaluation plan;

g) In failing to have a proper medical examination performed by a physician

to determine the Decedents medical needs and provide appropriate
medical care and treatment;

h) In failing to ensure the Decedent was seen and evaluated regularly by

medical personnel for breathing treatments and/or monitoring;

i) In failing to properly monitor the Decedent while on medical/suicide watch

so as to determine the severity of his condition;

j) Repeatedly failing to ensure that the Decedent was seen and evaluated by
a physician or immediately sent to a hospital;

k) In failing to properly train and/or supervise its employees, agents, and/or

staff, so as to ensure that detainees/inmates (including the Decedent) are
provided with proper medical care and attention while incarcerated;

l) In failing to have the proper policies and/or procedures in place regarding

the administration of proper medical care;

m) If such a policy and/or procedure exists, in failing to follow the same in

providing for the medical care necessary to ensure the Decedents well-
being;

n) In failing to take the appropriate steps to provide medical care and

treatment to the Decedent when they had actual and constructive notice of
the Decedents medical condition;

o) In failing to have the proper policies and procedures in place regarding

recognition of medical needs of new detainees;

p) In failing to draft and/or institute proper policy and procedure necessary

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to ensure that inmates are provided basic and/or appropriate medical care
and protection from abuse;

q) If said procedures do exist, in failing to follow same;

r) In failing to comply with national, state, and local standards and

guidelines with regard to the provision of medical care in detention
facilities;

s) In failing to provide and/or administer appropriate physical and/or mental

health exams in a timely manner to the detainees;

t) In failing to train their employees, agents, and/or staff to recognize the

medical needs of detainees;

u) In failing to properly treat and/or care for the Decedent, Mr. Floyd;

v) In failing to properly recognize the signs and symptoms of the Decedents

medical conditions;

w) In failing to provide, order, seek, and/or maintain emergency medical care;

x) In failing to refer and/or bring in the proper specialist and/or medical

doctor;

y) In abandoning the Decedent when he was in desperate need of medical

care;

z) In failing to have proper communication by and between the detention

officers and the medical personnel contracted to provide medical
assistance to the detainees;

aa) In failing to keep sufficient records regarding inmates so as to have a

proper medical history, which would prevent repeat situations, such as the
one described herein, from occurring;

bb) In failing to provide the appropriate number of detention staff at the

various locations in the Horry County Detention Center;

cc) In failing to provide adequate and appropriate security officers at the

Florence County Detention Center;

dd) In failing to properly monitor the detainees (including the Decedent) at the
Horry County Detention Center;

ee) In failing to properly train, monitor and supervise its personnel agents
and/or employees so as to ensure the safety of the detainees located at the
Horry County Detention Center;

ff) In failing to have appropriate policies and protocols in place to provide for

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the safety and wellbeing of the detainee population at the Horry County
Detention Center;

gg) If such policies exist, in failing to follow the same;

hh) Failing to follow and adhere to the policies and protocols of the South
Carolina Minimum Standards for Local Detention Centers;

AS TO THE DEFENDANTS SOUTHERN HEALTH PARTNERS,

AND CHARLES BUSH, M.D.
(Gross Negligence Survival)

(a) In failing to properly care for the Decedent, when the Defendants and/or
their personnel, agents, and/or employees knew or should have known
that the Decedent was in dire need medical assistance and/or treatment;

(b) In failing to provide reasonable, necessary, and appropriate medical

attention to the Decedent;

(c) In failing to monitor the Decedent, while incarcerated, and take the
proper steps to provide medical assistance to him when they knew or
should have known that he was in such a state that he was unable to
care for himself;

(d) In failing to ensure that the Decedent was seen by a physician;

(e) In failing to refer or transport the Decedent to a specialist and/or a

hospital;

(f) In failing to have a proper medical and/or mental health examination

performed by a physician to determine the Decedents medical needs and
provide appropriate medical care and treatment;

(g) In failing to sufficiently monitor the Decedent so as to determine the

severity of his condition;

(h) In failing to monitor the medical staff located at the Detention Center;

(i) In failing to monitor the detainees/patients located at the Detention

Center;

(j) In failing to ensure the Detention Center had the appropriate policies and
procedures regarding the provision of medical care to detainees;

(k) In failing to ensure that the medical policies and procedures were
implemented and/or followed;

(l) In failing to properly train and/or supervise its employees, agents,

and/or staff so as to ensure that detainees/inmates (including the

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Decedent) are provided with proper medical care and attention while
incarcerated;

(m) In failing to have the proper policies and/or procedures in place

regarding the administration of proper medical care;

(n) If such a policy and/or procedure exists, in failing to follow the same in
providing for the medical care necessary to ensure the Decedents well-
being;

(o) In failing to keep sufficient records regarding inmates so as to have a

proper medical history, which would prevent repeat situations, such as
the one described herein, from occurring;

(p) If such records are kept, in failing to take the time to check and/or refer
to the same;

(q) In failing to take the appropriate steps to provide medical care and
treatment to the Decedent when they had actual and constructive notice
of the Decedents medical condition;

(r) In failing to have the proper policies and procedures in place regarding
recognition of medical needs of new detainees;

(s) In failing to draft and/or institute proper policy and procedure necessary
to ensure that inmates are provided basic and/or appropriate medical
care and protection from abuse;

(t) If said procedures do exist, in failing to follow same;

(u) In failing to recognize that the Decedent had a serious medical condition
which required immediate medical attention;

(v) In failing to take emergent action after seeing that the Decedent had an
obvious serious medical condition;

(w) In failing to comply with national, state, and local standards and
guidelines with regard to the provision of medical care in detention
facilities;

(x) In failing to provide and/or administer appropriate physical and/or

mental health exams in a timely manner to the detainees;

(y) In failing to train their employees, agents, and/or staff to recognize the
medicals needs of detainees;

(z) In failing to properly respond to an emergency call/incident in a timely

fashion;

(aa) In failing to properly treat and/or care for the Decedent, Mr. Floyd;

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(bb) In failing to properly recognize the signs and symptoms of the Decedents
medical conditions;

(cc) In failing to properly stabilize the Decedents condition;

(dd) In failing to provide, order, seek, and/or maintain emergency medical

care;

(ee) In failing to refer and/or bring in the proper specialist and/or medical
doctor;

(ff) In abandoning the Decedent when he was in desperate need of medical

care;

(gg) In failing to have proper communication by and between the correctional

officers, and the medical personnel contracted to provide medical
assistance to the detainees;

(hh) In allowing the nurses located at the Detention Center to practice beyond
their scope.

23. As a result and because of the Defendants reckless, willful, wanton

and grossly negligent conduct, the Decedent suffered (both mentally and

physically) prior to his death. As a result, the Plaintiff is entitled to actual,

consequential and punitive damages in an amount to be determined by a

competent jury in accordance with the law and evidence in this case.

FOR A SECOND CAUSE OF ACTION AS TO THE DEFENDANTS

(Wrongful Death)

24. The Plaintiff reiterates each and every relevant allegation stated

above as if repeated verbatim herein.

25. This action is brought for the wrongful death of Jerome Floyd,

pursuant to the provisions of 15-51-10 et seq., Code of Laws of South

Carolina (1976, as amended), and is brought for the statutory heir(s) of Jerome

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Floyd, who died on the 20th day of August, 2015, as follows: his one (1) natural

child.

26. The death of the Decedent was caused and occasioned by the

negligent and grossly negligent acts on behalf of the Defendant as set forth

above.

27. Prior to his death, Jerome Floyd was 60 years of age. By reason of

his untimely death, his heir(s) has been deprived of all the benefits of his

society and companionship and have been caused great mental shock and

suffering by reason of his death. He has and will forever be caused grief and

sorrow by the loss of Mr. Floyds love, society, and companionship. He has been

deprived of his future experiences and judgments. He has incurred expenses

for his funeral and final expenses and, as a result of the foregoing, they have

been damaged as follows:

(a) mental shock and suffering;

(b) wounded feelings;
(c) grief and sorrow;
(d) loss of his support;
(e) loss of companionship; and
(f) deprivation of the use and comfort of the Decedents society
and loss of his experience, knowledge, and judgment.

28. As a further result, and because of the Defendants reckless, willful,

and grossly negligent conduct, which ultimately caused the wrongful death of

Jerome Floyd, this Plaintiff is entitled to actual, consequential, and punitive

damages in an amount to be determined by a jury in accordance with the law

and evidence in this case.

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WHEREFORE, the Plaintiff, in her fiduciary capacity as personal

representative of the Estate of Jerome Floyd, prays for judgment against the

Defendants, for ACTUAL and CONSEQUENTIAL damages, for the costs of this

action, and for such other and further relief as the Court may deem just and

proper.

s/C. Carter Elliott, Jr.

C. Carter Elliott, Jr., Esq.
Elliott & Phelan, LLC
P.O. Box 1405
Georgetown, SC 29442
Telephone: (843) 546-0650
Facsimile: (843) 546-1920
Attorney for the Plaintiff

June 14, 2017

Georgetown, South Carolina

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