Austin Griffith v. Franklin County, Ky.
975 F.3d 554
| 6th Cir. | 2020Background
- Austin Griffith was arrested on Nov. 8, 2015 and placed in Franklin County Regional Jail; he reported vomiting and was placed in a 48‑hour “detox” observation cell.
- Nurses (RN Heather Sherrow; LPN Sabina Trivette) screened Griffith Nov. 9–11, provided OTC meds, performed a urinalysis on Nov. 11 showing blood/protein, and placed him on a weekly APRN review list rather than immediate physician/APRN referral.
- After release to general population, Griffith suffered two seizures on Nov. 14; RN Brittany Mundine responded to the first seizure but returned him to his cell; after a second seizure she sent him to the ER; he had a third seizure and was airlifted to UK Hospital.
- Hospital diagnoses included acute renal failure and PRES; plaintiff continues to suffer sequelae.
- Griffith sued under 42 U.S.C. § 1983 (deliberate indifference under the Fourteenth/Eighth Amendments) and state tort claims; district court granted summary judgment for all defendants; the Sixth Circuit affirmed the judgment (majority) but issued a partial concurrence/dissent urging a different standard and result as to the nurses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper mens rea standard for pretrial‑detainee medical claims (effect of Kingsley) | Kingsley requires an objective test: detention‑condition claims need only objective recklessness (no subjective knowledge). | Traditional deliberate‑indifference test (subjective knowledge) remains controlling for medical claims; in any event the result is the same. | Court reserved the broader Kingsley question but held Griffith fails under either test—constitutional liability requires more than negligence. |
| Liability of nurses (Sherrow, Trivette, Mundine) for deliberate indifference | Nurses failed to escalate after abnormal urinalysis and after first seizure, causing deterioration to renal failure and seizures. | Nurses screened, tested, treated (OTC meds, Gatorade, Cipro), added him to APRN list, responded to seizures; their actions, even if imperfect, were not conscious disregard. | Summary judgment for nurses: evidence shows at most negligence/medical error, not deliberate indifference. |
| Supervisory / corporate liability (Dr. Waldridge, SHP) | Waldridge/SHP failed to supervise/train; systemic deficiencies caused the harm (Monell/failure‑to‑train). | No evidence that Waldridge encouraged/motivated misconduct or that SHP’s training was inadequate in this case. | Summary judgment for Waldridge and SHP: no underlying constitutional violation proved and no developed evidence of training/supervision defects. |
| Municipal liability (Franklin County / Jailer Rogers) | County had unofficial detox/customs of indifference and failed to train deputy jailers on EMS; county policies/practices caused harm. | Deputies checked every 20 minutes, medical staff saw Griffith multiple times, training exists; municipality not liable absent underlying constitutional violation or proof of custom/deliberate indifference. | Summary judgment for County and Jailer Rogers: plaintiff failed to show policy/custom, deliberate indifference, or causation. |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate‑indifference framework for prisoner medical care)
- Kingsley v. Hendrickson, 576 U.S. 389 (2015) (adopted objective‑reasonableness test for pretrial detainee excessive‑force claims)
- Farmer v. Brennan, 511 U.S. 825 (1994) (subjective deliberate‑indifference standard requires actual knowledge of substantial risk)
- Bell v. Wolfish, 441 U.S. 520 (1979) (pretrial detainee may challenge conditions that amount to punishment; analysis focuses on nonpunitive purpose and excessiveness)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability requires policy, custom, or deliberate indifference in training/supervision)
- LeMarbe v. Wisneski, 266 F.3d 429 (6th Cir. 2001) (deliberate indifference where obvious, extreme medical risk was observed and ignored)
- Blackmore v. Kalamazoo County, 390 F.3d 890 (6th Cir. 2004) (delay in treating an obvious medical need can satisfy objective prong)
- Rouster v. County of Saginaw, 749 F.3d 437 (6th Cir. 2014) (deference to medical judgments; misdiagnosis ≠ automatic constitutional violation)
- Richmond v. Huq, 885 F.3d 928 (6th Cir. 2018) (discusses applicability of Kingsley to pretrial detainee claims)
- Santiago v. Ringle, 734 F.3d 585 (6th Cir. 2013) (definition of a "sufficiently serious" medical need)