Michael Brinkley v. Hamilton County, Tenn.
24-5766
6th Cir.Mar 21, 2025Background
- Michael Brinkley, a pretrial detainee in Hamilton County Jail, Tennessee, reported concerns for his safety due to his gang affiliation and was relocated within the jail.
- After his transfer, Brinkley again felt threatened and, during a lockdown, noticed his cell was unlocked and unsuccessfully sought officer assistance.
- Brinkley was attacked and stabbed multiple times by fellow inmates who gained access to his cell.
- Brinkley sued the County and Sheriff Jim Hammond under 42 U.S.C. § 1983, alleging deliberate indifference to inmate safety and inadequate training/supervision practices (Monell claim), plus state law claims.
- The district court granted summary judgment to the defendants on federal claims and declined to consider the remaining state claims; Brinkley appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sheriff’s personal liability | Sheriff was responsible for failing to protect Brinkley | No evidence of Sheriff’s personal involvement | Dismissed—no personal involvement proven |
| Official capacity (Monell) claim | County’s inadequate training/supervision caused harm | No evidence of policy/custom, only allegations | Dismissed—no genuine dispute on policy/custom |
| Failure to protect (constitutional violation) | Suffered harm due to deliberate indifference | Jail responded to requests; no proof of deliberate indifference | Dismissed—no constitutional violation evidenced |
| Summary judgment | Sufficient evidence to survive summary judgment | No competent evidence, only conclusory allegations | Summary judgment affirmed |
Key Cases Cited
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (establishes municipal liability under section 1983 only for injuries caused by a government policy or custom)
- Grinter v. Knight, 532 F.3d 567 (6th Cir. 2008) (personal involvement required for individual liability under § 1983)
- Miller v. Calhoun County, 408 F.3d 803 (6th Cir. 2005) (clarifies standard for municipal and individual capacity claims under § 1983)
- Jackson v. City of Cleveland, 925 F.3d 793 (6th Cir. 2019) (summary judgment standard in § 1983 cases)