Cristi Campbell v. April Riahi, 109 F.4th 854

Bryana Baker, a pretrial detainee suffering drug withdrawal and mental health issues, committed suicide in Butler County Jail after being placed in disciplinary isolation for a failed escape attempt.
Baker had undergone multiple mental health evaluations; each time, she denied suicidal ideation and was ultimately removed from suicide watch, but was not cleared to be alone in a cell with the door closed.
On the day of her suicide, an escalating altercation between Baker and her cellmate led Officer Riahi to separate them by placing each in separate cells and closing their doors—despite Baker not being cleared for single-celling.
Baker’s mother sued Officer Riahi, Sheriff Jones, and Butler County under 42 U.S.C. § 1983 and Ohio law, alleging deliberate indifference to suicide risk and inadequate policies and training.
The district court granted summary judgment to all defendants; Baker’s mother appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Deliberate indifference under Fourteenth Amendment	Riahi was deliberately indifferent to Baker’s suicide risk by closing her cell door	Riahi acted reasonably, balancing risks, and is entitled to qualified immunity	Riahi is entitled to qualified immunity; no clearly established right was violated
Supervisory liability against Sheriff Jones	Jones is liable as Riahi’s supervisor under § 1983	No constitutional violation by subordinate; no basis for liability	No liability; prerequisite of subordinate’s constitutional violation not met
Municipal liability against Butler County	County had policies/customs showing deliberate indifference	No deliberate indifference; no violation of a clearly established right	No municipal liability; no underlying constitutional violation
State-law wrongful death/negligence claims	Riahi and Jones acted recklessly, so not immune under state law	Their acts were not reckless under Ohio standards; statutorily immune	Both immune; actions not found to be reckless or wanton

Farmer v. Brennan, 511 U.S. 825 (establishes the deliberate indifference standard for inmate harm)
Estelle v. Gamble, 429 U.S. 97 (sets constitutional standard for medical care in prisons)
Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (establishes standards for municipal liability under § 1983)
City of Revere v. Mass. Gen. Hosp., 463 U.S. 239 (confirms state’s constitutional obligation to protect detainees' health and safety)
Mullenix v. Luna, 577 U.S. 7 (clarifies qualified immunity and clearly established law)
District of Columbia v. Wesby, 583 U.S. 48 (restates qualified immunity standards)
County of Sacramento v. Lewis, 523 U.S. 833 (describes conditions for liability during exigent, rapidly evolving situations)
Ashcroft v. al–Kidd, 563 U.S. 731 (qualified immunity standard for clearly established law)
Beck v. Hamblen County, 969 F.3d 592 (details requirements and limits for deliberate indifference claims)
Arrington-Bey v. City of Bedford Heights, 858 F.3d 988 (municipal liability depends on clearly established rights at time of alleged violation)
Doe v. Claiborne County, 103 F.3d 495 (details deliberate indifference and municipal liability standards)