Barbara Bays v. Montmorency Cty., Mich.
874 F.3d 264
6th Cir.2017Background
- In April 2013, pretrial detainee Shane Bays reported severe psychiatric symptoms (paranoia, anxiety, hearing voices, agitation, violent impulses, self-harm) to Montmorency County jail nurse Donna Sigler during intake and multiple follow-ups.
- Sigler documented the symptoms, circled “yes” for mental-health emergency referral (noting “on discharge”), scheduled a mental-health clinic appointment for May 2, and twice sought earlier appointments but declined an earlier offered slot because transportation/guard coverage would be difficult.
- Sigler called a consulting jail mental-health nurse (Pilarski) but described only anxiety; Pilarski prescribed Benadryl. Sigler admitted she believed Bays should have been placed on a safety/watch list and later conceded she should have arranged more immediate care or called an ambulance.
- Between April 22–23, 2013, Bays hanged himself in the jail. His parents filed a 42 U.S.C. § 1983 suit against Sigler (individual liability) and Montmorency County (failure-to-train/municipal liability).
- The district court denied summary judgment as to Sigler (qualified immunity denied) and granted summary judgment to the County; Sigler appealed the denial of qualified immunity and the Bays cross‑appealed the County’s dismissal.
- The Sixth Circuit affirmed denial of qualified immunity to Sigler (finding triable fact issues on deliberate indifference to a serious mental-health need and that the right was clearly established) and dismissed the Bays’ cross-appeal of the County ruling for lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Sigler violated Fourteenth Amendment (deliberate indifference to serious medical need) | Bays: Sigler knew of severe psychiatric symptoms, failed to obtain prompt/adequate treatment or place Bays on watch list, and thus was deliberately indifferent. | Sigler: Symptoms did not show a serious condition requiring immediate intervention; at most negligent care or malpractice, not constitutional deliberate indifference. | Triable issue: affidavit evidence permits a jury to find Sigler was deliberately indifferent. |
| Whether the right to prompt psychiatric treatment was clearly established | Bays: Courts (including Sixth Circuit) have long recognized right to reasonable medical/psychological care for inmates/detainees. | Sigler: Case law (Taylor/Barkes) limits clearly established rights re: suicide-prevention procedures; no clearly established rule here. | Held clearly established: right to reasonable treatment of serious mental illness was sufficiently established. |
| Whether the County is liable for failure-to-train (municipal liability) | Bays: County failed to train jail medical staff, leading to constitutional violation. | County: Summary judgment proper; no final decision on municipal liability; appeal not final/interlocutory. | Dismissed for lack of jurisdiction: cross-appeal not inextricably intertwined with Sigler’s appeal; review left for after final judgment. |
| Whether pendent appellate jurisdiction applies to the Bays’ cross-appeal | Bays: Should be heard alongside Sigler’s appeal under pendent jurisdiction because claims arise from same facts. | County/Sigler: Cross-appeal not coterminous with qualified immunity issue; appellate resolution of Sigler’s immunity does not necessarily resolve municipal claim. | Court declined pendent jurisdiction; cross-appeal dismissed. |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate indifference standard for medical care of prisoners)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified-immunity two-step: constitutional violation and clearly established right)
- Farmer v. Brennan, 511 U.S. 825 (1994) (subjective deliberate indifference standard: officer must know of and disregard substantial risk)
- Clark-Murphy v. Foreback, 439 F.3d 280 (6th Cir. 2006) (recognizing that right to psychological treatment is cognizable under deliberate indifference doctrine)
- Taylor v. Barkes, 135 S. Ct. 2042 (2015) (limits on clearly established right as to implementation of suicide-prevention procedures)
- Plumhoff v. Rickard, 134 S. Ct. 2012 (2014) (appellate assumption that nonmovant's record-supported allegations are true when reviewing qualified immunity)
- Rouster v. County of Saginaw, 749 F.3d 437 (6th Cir. 2014) (treatment that is merely inadequate or negligent does not rise to deliberate indifference; constitutional violation requires more than malpractice)
- Harris v. City of Circleville, 583 F.3d 356 (6th Cir. 2009) (evidence standard for recognizing serious mental-health needs of detainees)