Cecil prison officers not liable for opioid withdrawal death, court rules

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Cecil County correctional officers are not liable for a woman’s 2020 death from opioid withdrawal behind bars, the U.S. Court of Appeals for the Fourth Circuit ruled this month.

A three-judge Fourth Circuit panel ruled Tuesday that the estate of Cynthia Rice, who died at the Cecil County Detention Center the day after she was booked, had failed to state specific claims against the 16 sheriff’s deputies named as defendants.

The court reversed a decision by Maryland U.S. District Judge Matthew Maddox, who ruled in 2024 that the officers were not entitled to qualified immunity at the motion-to-dismiss stage of the litigation and allowed the lawsuit to move forward.

“The complaint never connected any named officer to any culpable act or omission,” Fourth Circuit Judge Jay Richardson wrote in the published opinion. “So the district court should have dismissed it.”

Richardson was joined by judges Paul Niemeyer and G. Steven Agee. They heard arguments in October.

The sheriff’s deputies were represented by Jack Karpinski of Karpinski, Cornbrooks & Karp in Baltimore. Rice’s estate was represented by solo practitioner Randy Evan McDonald in Washington, D.C. Neither attorney immediately responded to a request for comment.

Rice was booked the night of August 28, 2020, and told unidentified officers and medical staff that she was addicted to heroin and suffering from withdrawal.

Medical staff from PrimeCare, a company that provides medical staff and care to the detention center, performed an intake screening around 3 a.m. They noted that she was anxious and had high blood pressure, and scheduled a “high priority” detox check, the opinion states.

Before 10 a.m., medical staff ordered an opioid-detox protocol and blood-pressure medication. At some point in the morning, according to the complaint, she “screamed and writhed in pain,” and correctional officers told her to “shut up.”

Around 12:30 p.m., an officer asked if she was OK, and she said she was not. Rice was unresponsive when prison personnel entered at some point after that. Emergency medical services responded and pronounced her dead. Her estate sued for negligence and wrongful death, among other claims, three years later.

The ruling only applies to the sheriff’s deputies. Certain claims against PrimeCare are still alive. Richardson wrote that the court took no position on whether Rice’s estate can amend the complaint with more specific allegations against the officers.

“The complaint never identified what any officer did or knew,” Richardson wrote.

“To allege that an officer acted with deliberate indifference, the complaint must make defendant-specific allegations. The allegations must be particular enough to allow one to infer what each defendant did and knew. Lumping defendants together won’t do.”