David Bruederle v. Louisville Metro Government
2012 U.S. App. LEXIS 15180
6th Cir.2012Background
- Bruederle arrested Dec 3, 2004 for assault; jail intake by CMS-nurse Smith; he reported long pain-medication history (hydrocodone, Xanax, Paxil, Flexeril, Ambien) and had not taken meds recently.
- CMS protocol deemed withdrawal risk low; Bruederle placed in medical dormitory due to potential withdrawal.
- Seizure occurred Dec 5 after attempting to stand; detox regimen prescribed and implemented; he later received Tylenol for pain.
- Post-seizure, nurses refused to administer meds; verification and physician-approval procedures delayed medication until Monday after arrest.
- District court granted summary judgment to defendants on § 1983 claims; denied Rule 59(e) relief; Bruederle appealed.
- Court ultimately affirmed the district court’s grant of summary judgment, finding no deliberate indifference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendants violated Due Process by deliberate indifference | Bruederle argues withdrawal risk and pain were ignored | Smith and CMS followed policies; no duty breached | No due-process violation; summary judgment proper |
| Whether jail policies or no-narcotics policy were responsible | There was an explicit no narcotics policy | Policy was not triggered or applied to this case | Policy not implicated; no policy-driven harm shown |
| Whether failure to provide meds before seizure showed deliberate indifference | Delay caused harm due to withdrawal | Screening and verification caused delay; not deliberate indifference | No deliberate indifference; reasonable medical judgment by staff |
| Whether Smith's screening conduct constitutes deliberate indifference | Smith should have recognized withdrawal risk | Smith reasonably assessed risk; placed in medical dormitory | Not deliberate indifference; judgment for defendants proper |
| Whether district court properly granted summary judgment on all claims | There were triable issues of fact | No genuine disputes on material facts; proper application of law | Affirmed; no reasonable juror could find constitutional violation |
Key Cases Cited
- Watkins v. City of Battle Creek, 273 F.3d 682 (6th Cir. 2001) (Due Process right to adequate medical care for inmates; two-prong test)
- Rhodes v. Chapman, 452 U.S. 337 (1981) (Eighth Amendment minimal life necessities; objective prong)
- Farmer v. Brennan, 511 U.S. 825 (1994) (Deliberate indifference requires knowledge of substantial risk and disregard)
- Heller v. City of Los Angeles, 475 U.S. 796 (1986) (No automatic constitutional objection to reasonable prison policies restricting drugs)
- Paige v. Coyner, 614 F.3d 273 (6th Cir. 2010) (Policy must be connected to the injury; flow-from-policy requirement)
- Bell v. Wolfish, 441 U.S. 520 (1979) (Prison policies balancing security and detainee rights; no per se violation)
- Chappell v. City of Cleveland, 585 F.3d 901 (6th Cir. 2009) (Identity disputes not always material where documentary evidence is clear)
- Scott v. Harris, 550 U.S. 372 (2007) (Non-contradicted version of events may bar factual disputes at summary judgment)