Maria Kulpa v. John Cantea
708 F. App'x 846
| 6th Cir. | 2017Background
- Bronislaw Kulpa, a pretrial detainee in Macomb County, was taken from a detox cell for medical evaluation after agitated, incoherent behavior; he was handcuffed behind his back.
- During transport he tripped/fell; officers took him to a holding cell rather than the medical unit because they considered him actively resistant.
- Officer John Cantea (≈300 lbs.) kneeled over Kulpa’s back/torso while other officers held Kulpa’s legs; video shows Cantea maintaining knee pressure for roughly 40–75 seconds.
- Officers then placed Kulpa in a restraining chair; he appeared limp/unconscious in video. Medical staff arrived several minutes later and could not revive him.
- Autopsy listed cause as arteriosclerotic and hypertensive heart disease exacerbated by restraint and exertion; experts testified Kulpa suffered profound hypoxia/asphyxiation from compression of his chest/back.
- Plaintiff sued officers and Macomb County under §1983 for excessive force (Fourteenth Amendment), failure to intervene, deliberate indifference to medical needs, and municipal failure to train; district court granted summary judgment to officers and dismissed the county; Sixth Circuit reversed in part and affirmed in part.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force by Cantea (pretrial detainee standard) | Cantea applied substantial body weight to Kulpa’s back while he was handcuffed/prone and incapacitated, causing asphyxiation and death | Force was lawful to maintain control; no clearly established law barred kneeling on a detainee absent malicious intent; experts cannot quantify exact weight | Reversed as to summary judgment: jury could find force objectively unreasonable and clearly established (Champion and pre-Kingsley precedent put officers on notice) |
| Failure to intervene (other officers) | Nearby officers observed Cantea apply excessive pressure and had opportunity/means to stop it but did nothing | At least one officer (Peck-Gagne) alerted medical; others had no individual culpability | Reversed as to summary judgment: material facts support liability for failing to intercede |
| Deliberate indifference to medical needs | Officers knew or should have known Kulpa was unconscious/not breathing and delayed emergency aid, causing death | Peck-Gagne called medical to request a routine check; that suffices and absolves others from immediate duty to call | Reversed as to summary judgment: jury could find officers disregarded substantial risk by delaying emergency care |
| Municipal failure to train (Macomb County) | County failed to train to avoid prone restraint/require specific chair procedures, causing violation | No clearly established constitutional rule requiring removal-of-handcuffs-after-placement-in-chair; plaintiff offers only one expert and no pattern of similar incidents | Affirmed: plaintiff failed to show constitutionally inadequate training or deliberate indifference by the county |
Key Cases Cited
- Kingsley v. Hendrickson, 135 S. Ct. 2466 (2015) (objective‑reasonableness standard for pretrial detainee excessive‑force claims)
- Champion v. Outlook Nashville, Inc., 380 F.3d 893 (6th Cir. 2004) (holding substantial pressure on a prone, handcuffed, incapacitated suspect can constitute excessive force)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity two‑step framework)
- Graham v. Connor, 490 U.S. 386 (1989) (reasonableness standard for force by officers)
- Whitley v. Albers, 475 U.S. 312 (1986) (factors bearing on need for force and proportionality)
- Estate of Owensby v. City of Cincinnati, 414 F.3d 596 (6th Cir. 2005) (deliberate indifference where officers observed severe distress but delayed medical aid)