Fuller v. Louisville Metro Government, 3:17-cv-00661

Matthew Fuller was detained at Louisville Metro Department of Corrections in June 2016; Correct Care Solutions provided on-site medical staff who treated him for fever, possible opioid withdrawal, constipation, and subsequent deterioration.
Medical notes show fever, elevated pulse, low oxygen saturation, diagnosis of dehydration, later concern for sepsis, and emergency transport on June 22; Fuller was intubated, diagnosed with septic shock and infective endocarditis, and died July 5, 2016.
Plaintiff Deborah Fuller sued Louisville Metro, Metro Corrections Director Mark Bolton, Correct Care, and individual Correct Care clinicians under 42 U.S.C. § 1983 and state law alleging deliberate indifference and related municipal/supervisory liability theories.
Louisville Metro and Director Bolton moved to dismiss claims against them for failure to state a plausible claim; Correct Care and individual clinicians remained as defendants.
The complaint alleged customs/policies caused inadequate care and conclusory failure-to-train/employ claims but contained no factual allegations linking Bolton or Louisville Metro to knowledge of Fuller’s condition, policy creation, or active participation in the alleged misconduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Deliberate-indifference against Director Bolton (individual capacity)	Fuller alleges defendants were deliberately indifferent to Matthew’s serious medical needs; construed to include Bolton	Bolton lacked personal knowledge or involvement; no facts show he knew of or disregarded a serious risk	Dismissed — complaint fails to plausibly allege Bolton’s knowledge or involvement
Monell municipal liability (Louisville Metro)	Fuller contends death resulted from customs/practices contrary to policies and failure to train/supervise	Metro argues no policy or custom alleged that caused the constitutional violation; pleadings are conclusory	Dismissed — complaint lacks factual allegations tying death to a Metro policy or longstanding custom
Supervisory liability against Bolton (failure to train/promulgate policy)	Plaintiff asserts Bolton failed to employ, train, supervise, or promulgate policies	Bolton argues no active unconstitutional behavior, no facts showing authorization, acquiescence, or causal link	Dismissed — mere conclusory allegations without factual nexus insufficient
State-law negligence and wrongful-death claims against Bolton	Fuller seeks to hold Bolton liable for subordinate negligence and supervisory failures	Bolton asserts Kentucky law requires direct involvement or knowledge to impose liability on a public official	Dismissed — no allegations that Bolton directly participated or knew subordinates were incompetent

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain factual content allowing a court to draw a reasonable inference of liability)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state a plausible claim, not mere labels and conclusions)
Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability under § 1983 requires an official policy or custom causing the violation)
Blackmore v. Kalamazoo Cty., 390 F.3d 890 (6th Cir. 2004) (deliberate indifference standard for prisoners/detainees requires objective and subjective components)
Miller v. Calhoun Cty., 408 F.3d 803 (6th Cir. 2005) (knowledge of a substantial risk is essential for deliberate indifference)
Watkins v. City of Battle Creek, 273 F.3d 682 (6th Cir. 2001) (deliberate indifference requires knowing disregard of substantial risk)
Peatross v. City of Memphis, 818 F.3d 233 (6th Cir. 2016) (supervisory liability requires active unconstitutional behavior by supervisor)
Shehee v. Luttrell, 199 F.3d 295 (6th Cir. 1999) (supervisory liability may require implicit authorization or acquiescence of unconstitutional conduct)
Horn v. Madison Cty. Fiscal Court, 22 F.3d 653 (6th Cir. 1994) (knowledge or circumstances clearly indicating serious need required for deliberate indifference)
Brown v. Bargery, 207 F.3d 863 (6th Cir. 2000) (subjective component requires sufficiently culpable state of mind)