Charolette Winkler v. Madison Cty., Ky.
893 F.3d 877
| 6th Cir. | 2018Background
- Brandon Clint Hacker was detained at Madison County Detention Center from April 30–May 5, 2014 and died of acute peritonitis from a perforated duodenal ulcer after five days in custody.
- Hacker reported symptoms consistent with opiate withdrawal and stomach pain; medical staff (an LPN, a remote nurse practitioner, and an on-call physician) treated him based on a diagnosis of withdrawal and prescribed Vistaril, Bentyl, and related medications.
- Nurse Johnson (LPN) evaluated Hacker on May 2 and relayed findings to Nurse Troutman (NP) by phone; Troutman diagnosed likely heroin withdrawal and ordered medications. Dr. Al‑Shami (on‑call physician) later approved/continued treatment after phone calls on May 4.
- Jail deputies and captains observed Hacker decline (weakness, sweating, vomiting, complaints of internal bleeding) at various times but generally relied on medical staff orders to “monitor” him; some deputies did not check vitals or escalate care before May 5.
- Hacker collapsed May 5; emergency services were called but resuscitation failed. Plaintiff Winkler (administrator of estate) sued under 42 U.S.C. § 1983 (Fourteenth Amendment pretrial-detainee medical care) and state tort claims against county, jail staff, Healthcare (private contractor), and individual medical providers.
- The district court granted summary judgment to all defendants on the § 1983 claim and declined supplemental jurisdiction over state claims; the Sixth Circuit affirmed. The court treated the facts as negligence/misdiagnosis, not deliberate indifference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether individual medical staff (Nurse Troutman, Dr. Al‑Shami, Nurse Johnson) were deliberately indifferent | Winkler: misdiagnosis, failure to follow protocols, inadequate monitoring amounted to subjective deliberate indifference | Defendants: they assessed symptoms as opiate withdrawal, provided treatment and instructions; deviations from protocol amount to negligence, not constitutional recklessness | Court: No. Treatment—even if suboptimal or negligent—did not evidence subjective knowledge of a substantial risk or reckless disregard; summary judgment affirmed |
| Whether nonmedical jail staff (deputies/captains) were deliberately indifferent by not escalating/monitoring | Winkler: deputies and captains ignored obvious signs and failed to seek/communicate necessary info or transport to hospital | Defendants: staff relayed info to medical providers, followed medical orders, and reasonably relied on physician instructions; some actions may be negligent but not consciously reckless | Court: No. Reasonable reliance on medical staff and lack of facts showing staff drew inference of substantial risk; summary judgment affirmed |
| Municipal liability — Madison County (Monell) for policies, customs, or failure to train/supervise | Winkler: County customually relied on Healthcare despite inadequate staffing/policies and failed to train deputies to monitor inmates when medical staff absent | County: contracting with private provider and existing policies were lawful; no pattern of prior constitutional violations or notice of a known risk | Court: No. Plaintiff failed to show a policy/custom or deliberate indifference by County (and cannot rely on single incident); summary judgment affirmed |
| Corporate liability — Advanced Correctional Healthcare (private contractor) for training/policies | Winkler: Healthcare failed to train/supervise staff and lacked adequate policies/procedures, producing constitutional harm | Healthcare: provided training and protocols; Plaintiff’s expert opinion and single adverse outcome insufficient to show deliberate indifference or a pattern | Court: No. Evidence of training and absence of proof of a persistent pattern of constitutional violations preclude Monell‑style liability; summary judgment affirmed |
Key Cases Cited
- Williams v. AT&T Mobility Servs., 847 F.3d 384 (6th Cir. 2017) (standard of review for summary judgment)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires subjective knowledge and disregard of substantial risk)
- Comstock v. McCrary, 273 F.3d 693 (6th Cir. 2001) (medical malpractice or negligence is not per se Eighth/Fourteenth Amendment violation)
- Rouster v. County of Saginaw, 749 F.3d 437 (6th Cir. 2014) (perforated duodenal ulcer case; differentiating misdiagnosis from deliberate indifference)
- Spears v. Ruth, 589 F.3d 249 (6th Cir. 2009) (two‑part deliberate‑indifference test for pretrial detainees)
- Jones v. Muskegon County, 625 F.3d 935 (6th Cir. 2010) (reliance on medical judgment and standards for individual/municipal liability)