judgment in our case we're asking for it to be reversed for two reasons one on the deliberate indifference going the lower court reviewed the evidence that we presented and all the in hobbes young did say that to pull the policies up to the to the level of the law is not appropriate so i would follow the reasoning and hobbs and actually also in the call case indifferent because they there's substantial evidence that all of them are in objective serious medical need that would have been obvious to any lay person and also that there was a the leg just delaying recently been in an accident that's what he said it was in the trooper that he couldn't find any evidence of but that is it and that is that it was drunk and that the medical people had been there then  jailers because they understand that but but but the highway patrolman saw all that that that made for a good for ok for our purposes at nine thirty they were at least alerted there was a known taylor tells him at that time repeats that he's been in a wreck and that he's complaining of stomach pains and that he's all busted up inside and that comes from the booking log and head off also come and specifically for almost tell you or it was parker that initially helped and bring him in as shown by the video but hundreds in testify as two hours later that he was the one who went to try to book him and i believe the booking must be the filling out  begging for help and that he was just about that and that he was he said he was dying and he was complaining all night and more specifically in my tail or says th case because that involves specifically a liver laceration where the the paramedics actually checked the fell out before he was taken to jail and could not find the gunshot wound that caused it but later at the jail the inmates were complaining of and other inmates were complaining that he was shot and he needed help and the jailers didn't get it get him help so i think that's probably the most analogous the four circuit circuit case but out throughout taylor's complaint they ignored him they they didn't they never went into his jail until jail i think the first time we have evidence that they may have went into the actual jail cells at five o'clock so how do we w immediately after that cast a lot of doubt own whether taylor would have said that to the defendant hohner because if you look at the descriptive language in that inmate both before and after any if you look at the nurse own testimony what they said it just didn't job with what hundred described if somebody is begging for help saying they are dying pleading for medical help so is that is that the right analysis i mean to do you have to see sort of x ray vision like through the prisoner's body to know what's going on inside you have to know specifically the condition that is ailing this person on the inside or do you just have to have an objective and subjective awareness of a medical need generally more than just medical i mean you know there was an obvious medical condition in that he was intoxicated  which let's call it a serious medical need i mean do they do they have to know or should have known that he was suffering from internal bleeding how with at how would they have of that well that's the point exactly how would a layperson where they were present and observe some type of injury that occur you know the classic cases you know case where and individual ended up being shot well you know if there's blood and there's if there's visible signs of some kind of injury well then no you know they would not have to be aware of the specific injury so you know if the bullet wound lacerated liver they would not have to be aware that well the bullet could have lacerated the liver or instances where officers have been present and have used a certain amount of force on an individual and in those situations the courts have said well you can't really be surprised in using force that some type of injury might have courage courage given these other circumstances but so the jury were asked to be there at the infliction or to witness the injury occurring or to rescue some external evidence of the injury if the jailer is not there and there is only internal injury that is not visible to be to the naked eye yet you went every time oh i don't know if every time but the but the rule is is that it has to be obvious to the la information of any potential injury that the officers may have known about it was dependent upon that being communicated by the by the state trooper and you know to to  address the assertion that trooper that trooper amos believed in me of me may have communicated that he had been in an accident the the record shows that could not have been the case trooper amos specifically testified that when he investigated the scene he did not believe there was an accident but what was it that he told parker then ok that's the important thing is what what did he tell parker out by e m s he's just intoxicated and then he further communicate in the afternoon if he's up and perky you can go ahead and release him you don't need to call me or anything you know th communication that trooper amos was giving to the officers was this was just a standard run of the mill dui for which you can hold individuals up to twenty four hours under alabama law ok but then begging for medical attention he was told by the guards to shut up now suddenly all the inference is untestable has to be given in favor of the plaintiff here you know for the purpose of summary judgment and qualified immunity risin thought enough to show that it would be general conclusion that they made and the opponents are asking as they did the district court to draw the inference that he cried all night for example in me scott who they just discussed who was in the jail five and a half hours before he initially in his deposition did say oh yes he he cried all night but later on being asked how how many times he stated he did not recall but more than five or six times he also admitted it may have been an hour before the first time he complained these are contained in document wanton thirty one pages thirteen eight hundred twenty three as well as pages thirty six one through eleven inmate garner who was supplied by affidavit he made the same general statement but paragraph of his eight of his affidavit contained in document one twenty eight thirteen stated i would do is off and on through the night and early morning hours and be awakened by mr taylor asking for help on several occasions now the record shows that inmate garner was in there for perhaps two hours so during those two hours while he dozed on and off he  heard him cry out a few times now at this point we're awfully close to five o'clock when officer hunter went into the room but what about walker youthen walker describes taylor as having screamed for hours i mean continuously nobody would help him and i mean he kept telling everybody and wouldn't nobody help him how long was he in there about an hour and so that would have the and you have to remember this time you know officer hunter had gone in to take his booking photograph which appears on there had spoken to him had asked the nurse if he could wait for an hour for the nurse so they were actively in here and i should point out something that didn't come out in the briefs that is also interesting about inmate walker's testimony regarding what had been communicated now according to mr taylor or excuse me according to to him it walker  stated that he spoke with taylor or at least overheard taylor told him that the state trooper had cleared him for a wreck and that he had been cleared but his chest was hurting him but they said that he had been cleared so he was fine in this isn't documented number one tendentious thirty two page thirty seven line seventeen through eighty eight or excuse me thirty eight lines five so here we have an inmate testifying to the fact that shortly before he died still the if you look at the substance of these inmates testimony it does not support the inference that mr taylor although he may have cried out at certain times sat and  draw reasonable inferences in favor of the nonmoving party the inference that mr taylor cried out all night is not a reasonable inference so so on your timeline scott plus walker plus garner does not equal reasonable inference that he cried out for a long time it supports the inference that he cried out at various times you would support scott that he's cried out for four five or six times and another thing that we should take a look at regarding this as well is the nurse the jail nurse who came in at around six o'clock she first heard her testimony was when she first heard could have him crying out the christ  but officer hunter immediately upon nurse nurse reeves arriving at the jail went to her and reported that he had stated reported to her that he said he had been an a ccident but that he had been medically cleared and still officer hunter while recording that information at some point in the night he did document and well your honor they would have had that would have had it been sufficient facts available for them to have even drawn an inference that he had a serious medical need that he had that he was not only suffering from intoxication but suffering  bleeding which some kind of serious medical condition but some kind of serious medical condition back to my question not i have this delp this lingering doubt that they spent have to know specifically that he's suffering from internal bleeding well really that you can't say that they have to know the precise medical condition known or are and i'm not saying that they do have to know a specific injury but what they are but when you have an injury as such as internal bleeding that's hidden you know they have to have some information that could indicate there was some he was drunk out of control couldn't drive or anything else but that officer that that the medics had been there and that the head examined him and they asked that he didn't want to go to a face the situations where they are not aware of the facts in this case the officers weren't aware of all the facts and you could say that trooper amos albeit unintentionally let me ask you one more if you don't mind i take it it's undisputed maybe it may not matter legally because they're not pressing the jail policy argument but i take it a done disputed that the jail policy that would ordinarily prevent these guys from allowing someone into the jail who was so visibly intoxicated that he couldn't walk under his own power right there is a policy that says we don't let people in who are so drunk that they can't walk themselves around and so somehow this guy perceived gave them to believe that he had medically cleared and i guess the reason i ask is that sort of help mike that way in the balance of what the officers reasonably could have assumed about his condition if there is a policy that says we don't let crazy drunk people into our jail just don't do it and maybe unintentionally he got into the jail here but if these guys are operating under that policy we live in a world in which we don't let incapacitated  brought people into the jail then later during the middle of the night when he's crying out does that make it more or less reasonable that they should assume that he was  as in this got into the testimony that came in through experts more in the district court but as you get individuals who are heavier drinkers which this individual's liver proved him to be  put it bluntly what is stinking drunk for someone who is a who drinks a life is entirely different than someone who drinks moderately so you know in dying when he's hollering that he's dining he's begging for medical help and that he's in pain you can infer from that that he's in pain and in so i think you don't have to show the specific injury stage at the summary judgment stage those inferences have to be taken in the light most favorable to mr taylor not to the defendant and that's what we have here they want to ignore everything that happened they want this court to ignore everything that happened after he came in and talked with the troopers and then just ignore everything else and that's not how the law works it what the evidence showed in this case was that his condition worsened throughout the night and they did nothing i think there was a question about whether you had outward signs like bleeding or you know something like that and the point here is they wouldn't know because they never walked into the jail and investigated and they never walked into the jail to make any quark in any inquiry and based on the fact that the defendant was saying man i'm busted up inside i've got abdominal pain all they would have to do is just what the nurse did lift up assured him that would solve the road rash and the bruises from being in from from the injuries but they didn't do that for five hours from eleven twenty seven till six thirty they ignored everything the inmate said happened and they did it the testimony about about the five or six times that was that was the number of times the jailers walked by walked by his sail at night