Amick v. Ohio Department of Rehabilitation & Correction, 521 F. App'x 354

Harry J. Amick, age 47, died in Belmont Correctional Institution after a fight with another inmate; death followed alleged withdrawal of psychotropic medications.
Amick had a long history of schizoaffective disorder and was previously treated with zyprexa and depakote; prescriptions were tapered and ultimately stopped during confinement.
Amick was moved among several Ohio facilities between April and September 2008; during most of this period he did not receive mental health treatment or medications.
On September 18, 2008, Amick was placed in a single cell after allegedly unsafe prescript by psychiatric staff; later that day he was attacked by another inmate and died from the injuries.
Amick’s estate and wife brought § 1983 claims for deliberate indifference to medical needs and for failure to protect, plus a failure-to-train/supervise theory; the district court dismissed under Rule 12(b)(6).
On appeal, the Sixth Circuit affirmed dismissal of some claims but vacated and remanded regarding at least one failure-to-protect claim against specific officers for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Deliberate indifference to medical needs	Amick’s condition worsened off meds; staff knew of risk and disregarded it.	No clearly increasing symptoms or substantial risk; decisions to taper meds were appropriate and no conscious disregard.	No deliberate indifference; subjective component lacking.
Failure to protect from inmate violence	Corrections officers delayed protection during the Henderson fight despite obvious risk.	No knowledge that fight was imminent or occurring; delay could be negligence, not deliberate indifference.	Claim plausibly stated against several officers; remanded for further proceedings on Jackson and others.
Policy or custom of inadequate training/supervision	Deliberate indifference to medical needs was due to training/supervision failures.	Without a viable underlying deliberate-indifference claim there is no policy-based liability.	Affirmed dismissal; no independent policy or custom claim viable without underlying § 1983 violation.

Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires objective and subjective components)
Twombly v. Bell Atl., 550 U.S. 544 (2007) (plausibility pleading standard)
Iqbal, 556 U.S. 662 (2009) (pleading must show plausible entitlement to relief)
Quigley v. Thai, 707 F.3d 675 (2013) (reckless exposure to risk; distinguishable from obvious risk)
Flanory v. Bonn, 604 F.3d 249 (6th Cir. 2010) (deliberate indifference standard in Eighth Amendment medical claims)
City of Los Angeles v. Heller, 475 U.S. 796 (1986) (supervisor liability and policy-based claims require underlying constitutional violation)
Woods v. Lecureux, 110 F.3d 1215 (6th Cir. 1997) (evidence admissions and pleading standards in § 1983 actions)