Cindy Shadrick v. Hopkins Cnty., Kentucky
805 F.3d 724
6th Cir.2015Background
- Butler admitted to Hopkins County Detention Center (HCDC) for a short jail stay and died three days later from an untreated MRSA infection.
- Shadrick, Butler’s mother, sued SHP under 42 U.S.C. § 1983 for failure to train/supervise SHP nurses and for negligence.
- District court granted SHP summary judgment on § 1983 and negligence claims; Shadrick appeals.
- Butler’s admission showed SHP nurses or agents failed to assess his condition, follow MRSA protocols, or obtain physician orders.
- SHP contracted with Hopkins County to provide medical care; the contract stated SHP was an independent contractor and that SHP would indemnify the county; SHP operated nationwide through a private corporate structure.
- Evidence indicated SHP lacked a formal training program for LPNs, relied on informal practices, and failed to monitor Butler’s deteriorating condition through multiple shifts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether SHP’s failure to train/supervise LPNs supports §1983 liability | Shadrick asserts deliberate indifference via inadequate training. | SHP contends no pattern or single-incident liability; no deliberate indifference proven. | Yes; genuine issues of material fact preclude summary judgment. |
| Whether SHP is liable for negligence and immune under Kentucky law | Shadrick argues SHP lacks immunity; negligence claim viable. | SHP seeks governmental immunity via Comair; argues origin/functional test. | Negligence claim not barred by immunity; summary judgment inappropriate. |
| Whether SHP’s immunity status under Comair extends to SHP as county contractor | Not fully addressed; SHP should not receive immunity as non-governmental origin. | SHP performs a governmental function and may lack origin immunity. | SHP not entitled to governmental immunity; but see dissent on official-immunity analysis. |
Key Cases Cited
- City of Canton v. Harris, 489 U.S. 378 (U.S. 1989) (deliberate indifference standard for training/municipal liability)
- Connick v. Thompson, 563 U.S. 51 (U.S. 2011) (pattern-or-single-incident theories of liability refined; training failure not always Monell liability)
- Comair, Inc. v. Lexington-Fayette Urban Cnty. Airport, 295 S.W.3d 91 (Ky. 2009) (origin vs function framework for governmental immunity)
- Jerauld ex rel. Robinson v. Kroger, 353 S.W.3d 636 (Ky. Ct. App. 2011) (private medical provider entitled to qualified official immunity when contracting to provide inmate care)
- Autry v. Western Kentucky University, 219 S.W.3d 713 (Ky. 2007) (university-created entity entitled to governmental immunity observed in specific context)
- Yanero v. Davis, 65 S.W.3d 510 (Ky. 2001) (defining qualified official immunity elements)
- D'Ambrosio v. Marino, 747 F.3d 378 (6th Cir. 2014) (monell liability and Brady-type concerns analogized to training context)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference standard—objective and subjective components)
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (constitutional right to medical care in prison context)