Richko Ex Rel. Horvath v. Wayne County, 819 F.3d 907

Horvath, a pretrial detainee, died after being beaten and stabbed by Gillespie in the Wayne County Jail’s 4SW unit on Sept. 21, 2011.
Linda Richko, as Horvath’s estate personal representative, sued Wayne County and jail personnel under 42 U.S.C. § 1983 and related statutes for deliberate indifference to Horvath’s safety.
Gillespie had a significant mental-health history; Gillespie was placed in Horvath’s cell in 4SW after Horvath requested a move due to a broken toilet.
A duty station officer and medical staff were aware of Gillespie’s mental-health history and medication status, but records review and isolation measures were not thoroughly pursued.
The district court denied summary judgment to the defendants; the defendants appealed on qualified-immunity grounds; Wayne County sought pendent jurisdiction.
The Sixth Circuit affirmed the district court as to the individual defendants but dismissed Wayne County’s interlocutory appeal for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Cameron, Stinson, Williams violated Horvath’s rights and are not entitled to qualified immunity.	Richko/horvath argue officers ignored substantial risk from Gillespie’s history.	Cameron/Stinson/Williams contend no deliberate indifference or clearly established rights were violated.	Denied qualified-immunity summary judgment; issues for trial.
Whether Wayne County’s appeal is proper on interlocutory review given qualified-immunity rulings.	Wayne County seeks pendent appellate review of policy liability.	County argues appeal is tied to immunity rulings.	Dismissed for lack of pendent jurisdiction; not coterminous with immunity ruling.

Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (duty to protect inmates from violence; objective/subjective components)
Wilson v. Yaklich, 148 F.3d 596 (6th Cir. 1998) (inmate protection duties extend to pretrial detainees)
Thompson v. Medina County, 29 F.3d 238 (6th Cir. 1994) (Fourteenth Amendment rights of pretrial detainees parallel Eighth Amendment analysis)
Mitchell v. Forsyth, 472 U.S. 511 (U.S. 1985) (standard for appellate review of qualified immunity)
Stoudemire v. Mich. Dept. of Corr., 705 F.3d 560 (6th Cir. 2013) (de novo review of denial of qualified-immunity motion)
Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (courts may address the two prongs in any order)
Johnson v. Jones, 515 U.S. 304 (1995) (limits interlocutory review of qualified immunity to legal questions)
Swint v. Chambers Cnty. Comm’n, 514 U.S. 35 (U.S. 1995) (pendent jurisdiction and collateral-order doctrine limits)
Meals v. City of Memphis, Tenn., 493 F.3d 720 (6th Cir. 2007) (municipality cannot shield liability by immunity of officers)
Scott v. Harris, 550 U.S. 372 (U.S. 2007) (summary-judgment standard; not blatantly contradicted record)
Garretson v. City of Madison Heights, 407 F.3d 789 (6th Cir. 2005) (subjective component must be evaluated for each officer)