Denise Coley v. Lucas County, Ohio, 799 F.3d 530

Carlton Benton, a pretrial detainee, died in Lucas County jail in 2004 after an incident involving jail staff.
Benton was shackled and restrained when Schmeltz allegedly shoved him, causing him to fall and strike his head on the cement floor; Gray and others witnessed the event.
In the medical unit Benton was restrained on a bed; Schmeltz allegedly restrained him further and Gray allegedly placed Benton in a chokehold, rendering him unconscious.
Gray allegedly left Benton unconscious and did not inform medical staff; other deputies found him later and Benton died days later after hospitalization.
Schmeltz and Gray allegedly falsified reports and lied to FBI agents to cover up the incident; the coroner initially attributed Benton’s death to natural causes.
Plaintiffs filed a 2008 complaint asserting § 1983 violations and state-law claims; the district court denied immunity defenses, and the case proceeded to appellate review on immunity grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether pretrial detainees’ excessive-force claims were properly analyzed under Fourteenth Amendment standards	Benton’s rights were violated by gratuitous force.	A different standard should apply or the injury sufficiency defeats claims.	Fourteenth Amendment standard applied; claims viable against Schmeltz and Gray.
Schmeltz’s shove constitute gratuitous force in violation of clearly established law	Shove was gratuitous and punitive toward a restrained detainee.	Actions were in the line of maintaining order.	Schmeltz violated clearly established law; liability deemed proper.
Gray’s use of a chokehold on Benton violated constitutional rights	Chokehold on a restrained, near-unconscious detainee was unlawful.	Chokehold justified by perceived threat or control needs.	Gray violated clearly established law; liability proper.
Telb’s personal liability for failure to train and supervise	Telb failed to train and supervise on use of force and medical care.	Insufficient basis for personal liability under supervision standards.	Plaintiffs plausibly stated a § 1983 failure-to-train/supervise claim against Telb.
Ohio statutory immunity under § 2744.02 for Telb and ratification under § 311.05	Telb ratified deputies’ misconduct by tolerating or concealing it; immunity should fail.	Immunity or ratification defenses should bar claims.	Telb not immune; ratification found under Ohio Rev. Code § 311.05; immunity defenses rejected.

Kingsley v. Hendrickson, 135 S. Ct. 2466 (U.S. 2015) (pretrial detainee excessive-force standard: objectively unreasonable force)
Graham v. Connor, 490 U.S. 386 (U.S. 1989) (reasonableness standard for excessive force during arrest)
Bell v. Wolfish, 441 U.S. 520 (U.S. 1979) (facility management and security considerations in confinement)
Pelfrey v. Chambers, 43 F.3d 1034 (6th Cir. 1995) (excessive force against restrained detainee under Eighth Amendment concepts)
Phelps v. Coy, 286 F.3d 295 (6th Cir. 2002) (unprovoked assault of arrestee can violate Fourth Amendment)
United Pet Supply, Inc. v. City of Chattanooga, 768 F.3d 464 (6th Cir. 2014) (supervisor liability and notice for qualified-immunity analysis)
Clemente v. Vaslo, 679 F.3d 482 (6th Cir. 2012) (clearly established rights analysis in qualified immunity)
Anderson v. Creighton, 483 U.S. 635 (U.S. 1987) (clearly established standard for qualified immunity)
Haynes v. Marshall, 887 F.2d 700 (6th Cir. 1989) (use of force against detainee and related immunity considerations)
Lambert v. Clancy, 927 N.E.2d 588 (Ohio 2010) (framework for Ohio immunity analysis under RC 2744)