Peart v. SENECA COUNTY, 808 F. Supp. 2d 1028

Peart, an immigration detainee in Seneca County Jail, was assaulted by inmate White in June 2008, sustaining skull fracture and brain injuries.
Peart sued Seneca County, Sheriff Steyer, and Commissioners Nutter, Sauber, and Bridinger under 42 U.S.C. § 1983 for Eighth/ Fourteenth Amendment violations and for state-law negligence and a claim under Ohio Rev. Code § 2921.44.
Defendants moved for summary judgment, challenging county capacity, § 1983 liability, and state-law immunity defenses.
Seneca County housed immigration detainees under an ICE contract; classification forms were not completed for Peart or White, and relevant risk-assessment procedures were not followed.
Evidence suggested the Sheriff and jail officials ignored or inadequately performed inmate classification, potentially creating a substantial risk of harm to inmates.
The court denied summary judgment in part and granted in part, allowing § 1983 liability based on potential policy/custom and denying immunity defenses, with specific rulings on the § 2921.44 claim and some immunity questions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Seneca County is a proper defendant under § 1983.	Peart treats the county as an applicable municipal defendant.	Seneca lacked capacity to be sued under Ohio law.	Seneca County proper defendant for § 1983.
Whether the § 1983 claim survives given alleged policy or custom of non-classification.	Non-classification created substantial risk and violated constitutional duties.	No formal policy or custom; random attack.	A jury could find a policy or custom and deliberate indifference.
Whether individual defendants are entitled to qualified immunity.	Rights to safe housing and proper classification are clearly established.	Rights asserted are not clearly established against supervisors.	Qualified immunity avoided for conclusions, not granted; facts could show violation and clearly established right.
Whether Ohio state-law immunity applies to the negligence claim and § 2921.44 applicability.	§ 311.05 imposes liability for deputies; § 2921.44 may not bar civil claims.	Immunity bars some state-law claims; § 2921.44 cannot support civil liability.	§ 2921.44 claim dismissed; immunity analysis proceeded with § 311.05 potentially imposing liability; remaining state-law issues unresolved.

Monell v. Dep't of Soc. Servs., 436 U.S. 658 (1978) (establishes local government liability for policy or custom under § 1983)
Farmer v. Brennan, 511 U.S. 825 (1994) (duty to take reasonable measures to protect inmates from harm; deliberate indifference standard)
Jett v. Dallas Indep. Sch. Dist., 491 U.S. 701 (1989) (clarifies final policymaker concept for municipal liability)
Pembaur v. Cincinnati, 475 U.S. 469 (1986) (final policymaker standard for municipal liability; who can establish policy)
City of Canton v. Harris, 489 U.S. 378 (1989) (deliberate indifference standard linked to training proposals and liability)
Calderon-Ortiz v. LaBoy-Alvarado, 300 F.3d 60 (1st Cir. 2002) (jailer duties to classify or separate potentially violent inmates; due process concerns)
Greene v. Bowles, 361 F.3d 290 (6th Cir. 2004) (supervisor liability when placements create vulnerability to attack)
Taylor v. Mich. Dep't of Corr., 69 F.3d 76 (6th Cir. 1995) (supervisor liability for improper inmate placement)