67 F.4th 302
6th Cir.2023Background
- Cornelius Howell, a pretrial detainee with diagnosed sickle cell disease, exhibited severe pain, numbness, repeatedly fell, and rated pain 10/10 while at Hamilton County Jail on Dec. 9, 2018.
- Nurse Christina Jordan evaluated Howell, knew of his sickle cell history (including prior hospitalizations), concluded he was having a psychiatric episode, ordered a restraint chair and transport to the jail mental-health observation unit, and did not send him to a hospital.
- Howell was strapped into a restraint chair in a locked observation cell; jail officers (including Deputies Erwin and Collini) performed sparse, visual checks (through a small door window), falsified log entries, did not perform required hourly removal/limb rotations/water/restroom offers, and found Howell dead ~4 hours later.
- Autopsy and expert opinions concluded Howell died from complications of a sickle cell crisis (Estate’s expert: rhabdomyolysis precipitated by exertion); NaphCare’s expert gave alternative cause.
- The Estate sued under 42 U.S.C. § 1983 for Fourteenth Amendment deliberate indifference and excessive force, and asserted Monell and failure-to-train claims; the district court granted summary judgment to all defendants.
- The Sixth Circuit affirmed summary judgment in part, reversed in part (as to Nurse Jordan and Deputy Erwin on deliberate indifference), found Erwin not entitled to qualified immunity, and remanded for further proceedings (including reconsideration of supplemental jurisdiction over related state-law claims).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference — Nurse Jordan | Jordan knew Howell’s sickle cell history and symptoms and failed to send him to hospital or provide treatment. | Jordan reasonably diagnosed a psychiatric episode; reasonable misdiagnosis shields liability. | Reversed: triable issue — jury could find Jordan recklessly ignored an obvious, unjustified risk. |
| Deliberate indifference — Nurse Periette Arthur | Arthur checked Howell once despite low BP and should have monitored/called a doctor. | Arthur had limited exposure, reasonably relied on Jordan’s assessment, and did not know Howell had sickle cell. | Affirmed: summary judgment for Arthur. |
| Deliberate indifference — Deputy Daniel Erwin | Erwin observed alarming signs, was tasked with monitoring, failed to perform adequate checks and falsified logs. | Erwin reasonably deferred to medical staff who ordered observation in the unit. | Reversed: triable issue — jury could find Erwin’s monitoring was recklessly inadequate; no qualified immunity. |
| Deliberate indifference — Deputy Matthew Collini | Collini failed to perform timely/in-person checks and falsified logs. | Collini lacked knowledge of the sallyport observations and reasonably deferred to medical staff. | Affirmed: summary judgment for Collini (conduct did not rise above negligence). |
| Deliberate indifference — Sgt. Justin Hunt | Hunt delayed limb rotation and supervisory duties. | Hunt was not primarily responsible for ongoing checks and deferred to medical staff. | Affirmed: summary judgment for Hunt (at most negligence). |
| Excessive force — Nurse Jordan (restraint chair) | Placing Howell in restraint chair and leaving him restrained was punitive/ excessive. | Restraint chair was reasonably related to safety/observation; no excessive force shown. | Affirmed: no genuine dispute that use of restraint chair was objectively unreasonable. |
| Monell / NaphCare custom — nurses ordering restraints | NaphCare had a custom of nurses authorizing restraint chairs that caused inadequate care. | No evidence of a widespread practice violating policy; single testimony insufficient. | Affirmed: summary judgment for NaphCare on Monell claim. |
| Failure-to-train — Hamilton County | County training on restraint-chair monitoring was inadequate and caused the violation. | County provided academy, orientation, and ongoing on-the-job training; training not shown deficient in substance. | Affirmed: summary judgment for County on failure-to-train claim. |
Key Cases Cited
- Brawner v. Scott County, 14 F.4th 585 (6th Cir. 2021) (adopting civil-recklessness standard for pretrial-detainee deliberate indifference)
- Farmer v. Brennan, 511 U.S. 825 (1994) (subjective knowledge standard for deliberate indifference)
- Kingsley v. Hendrickson, 576 U.S. 389 (2015) (objective-unreasonableness standard for pretrial detainee excessive force)
- Monell v. Department of Social Services of the City of New York, 436 U.S. 658 (1978) (municipal liability for unconstitutional policies or customs)
- Greene v. Crawford County, 22 F.4th 593 (6th Cir. 2022) (analysis of officer reliance on medical judgment and adequacy of observation)
- Phillips v. Roane County, 534 F.3d 531 (6th Cir. 2008) (denying qualified immunity where officers inadequately monitored detainee with alarming symptoms)
- Jones v. Muskegon County, 625 F.3d 935 (6th Cir. 2010) (misdiagnosis alone may not be deliberate indifference where treatment steps were reasonable)
- Connick v. Thompson, 563 U.S. 51 (2011) (failure-to-train municipal-liability framework)