Anita Arrington-Bey v. City of Bedford Heights, 858 F.3d 988

Omar Arrington-Bey exhibited delusional and agitated behavior at a Lowe’s after being fired; police found psychiatric pills on him and his mother said he was bipolar and off meds.
Bedford Heights officers arrested and transported Omar to the city jail; they relayed his behavior and the pills to jail staff but did not take him to a hospital.
Jail intake officers placed Omar in seclusion, delayed booking/psych screening until he calmed, and performed a medical screening in which Omar denied psychiatric care.
Hours later, after being uncuffed to make a phone call, Omar assaulted officers, was restrained, became pulseless, and died; autopsy attributed death to a sudden cardiac event associated with bipolar disease.
Plaintiff Anita Arrington-Bey sued the arresting officers, jail staff, the city, and a doctor under 42 U.S.C. § 1983 (Fourteenth Amendment) and Ohio state law; the district court denied immunity to most defendants and allowed federal and state claims to proceed.
The Sixth Circuit reversed, holding officers entitled to qualified immunity and that Ohio law did not show recklessness; it also rejected the Monell failure-to-train claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers violated a pretrial detainee's Fourteenth Amendment right to medical care	Arrington-Bey: officers were deliberately indifferent by failing to obtain immediate medical/psychiatric treatment for Omar	Officers: they relayed information, followed procedures, and reasonably detained him at the jail rather than a hospital	No clearly established constitutional violation; qualified immunity for officers
Whether the City is liable under Monell for failure to train	Arrington-Bey: municipal training was inadequate to detect/treat serious mental conditions, causing death	City: no clearly established right existed so cannot show deliberate indifference by policymakers	Monell claim fails because no clearly established right; no deliberate indifference shown
Whether state-law claims survive Ohio immunity protections	Arrington-Bey: officers acted recklessly/wanton in depriving Omar of required medical care	Officers/City: conduct, at most, negligent or reasonable under circumstances; Ohio immunity applies	Ohio immunity applies; plaintiff did not show wanton/reckless conduct
Whether any defendant forfeited qualified immunity by conduct so plainly unlawful	Arrington-Bey: facts are sufficiently similar to precedents to give officers clear notice	Defendants: no precedent placed them on clear notice to act differently under these facts	No precedent with similar facts; officers are protected except for one dismissed doctor already given immunity

Pearson v. Callahan, 555 U.S. 223 (qualified immunity two-prong framework)
Ashcroft v. al-Kidd, 563 U.S. 731 (clearly established law cannot be defined at high level of generality)
Anderson v. Creighton, 483 U.S. 635 (clearly established requirement)
Saucier v. Katz, 533 U.S. 194 (dispositive inquiry: would a reasonable officer know conduct was unlawful)
White v. Pauly, 137 S. Ct. 548 (need for closely analogous cases to overcome qualified immunity)
Monell v. N.Y.C. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability for failure to train)
City of Canton v. Harris, 489 U.S. 378 (deliberate indifference standard for failure-to-train claims)
Estate of Carter v. City of Detroit, 408 F.3d 305 (pretrial detainee right to medical care established)
Clark-Murphy v. Foreback, 439 F.3d 280 (deliberate indifference where severe medical need ignored)
Hagans v. Franklin Cty. Sheriff’s Office, 695 F.3d 505 (municipal liability and qualified immunity interplay)