Kenyatta Bridges v. Thomas Dart, 950 F.3d 476

Kenyatta Bridges, a pretrial detainee at Cook County DOC, had a medical record prescribing a lower bunk from March 26 to September 24, 2014.
Despite an electronic alert reflecting that prescription, Bridges was placed in an upper bunk and fell from it on April 24, 2014, sustaining injuries.
Bridges sued Sheriff Thomas Dart (official capacity) and Cook County under 42 U.S.C. § 1983, alleging a policy or widespread practice of ignoring lower-bunk prescriptions.
To prove a municipal custom, Bridges relied on several prior detainee lawsuits (originally five; three relied on at appeal), two of which settled and one dismissed.
The district court granted summary judgment for defendants; the Seventh Circuit affirmed, concluding the prior incidents were too few and disconnected to establish a widespread custom or municipal liability.
The court noted that objective-reasonableness is the standard for pretrial-detainee medical claims but found the claim would fail under either that standard or deliberate indifference.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether County had municipal policy/custom of ignoring lower-bunk prescriptions	Prior lawsuits show a widespread, persistent practice of ignoring prescriptions	Incidents are isolated, too few, and not linked to official policy; settlements/dismissals don't prove custom	Insufficient evidence of a widespread custom; summary judgment for defendants
Applicable constitutional standard for pretrial-detainee medical claims	Claimed deliberate indifference to medical needs	Objective-reasonableness governs pretrial detainee claims; alternatively, claim fails either way	Court applied objective-reasonableness but held claim fails under either standard
Admissibility and weight of other inmates' complaints/lawsuits as notice	Prior complaints put County on notice of ignored prescriptions	Complaints are unverified, settled/dismissed, and do not prove defendants knew complaints were legitimate	Court assumed complaints admissible for summary-judgment purposes but found them inadequate to show municipal notice or acquiescence
Whether number/timing of incidents suffices to show a widespread custom	Three to five incidents over seven years demonstrate a pattern	In a large county/jail system, that number is too few to show pervasive practice	Three–five incidents over seven years are legally insufficient to establish a widespread, policy-like custom

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
Monell v. Dep’t of Social Servs. of the City of New York, 436 U.S. 658 (municipal liability requires a policy, decisionmaker act, or widespread custom)
City of Canton, Ohio v. Harris, 489 U.S. 378 (municipal liability requires showing that the entity caused the constitutional violation)
Connick v. Thompson, 563 U.S. 51 (official municipal policy includes practices so persistent and widespread as to have the force of law)
Thomas v. Cook County Sheriff’s Dep’t, 604 F.3d 293 (widespread custom requires more than isolated incidents)
Grieveson v. Anderson, 538 F.3d 763 (few incidents do not establish a widespread unconstitutional practice)
Estate of Moreland v. Dieter, 395 F.3d 747 (three incidents insufficient to show a municipal custom)
Gable v. City of Chicago, 296 F.3d 531 (three incidents over years too few to impute policymaker notice)
Phelan v. Cook County, 463 F.3d 773 (plaintiff must show unlawful practice was so pervasive that policymakers’ acquiescence amounted to a policy)