Ruiz-Bueno v. Scott
639 F. App'x 354
6th Cir.2016Background
- Edward Peterson, a pretrial detainee with known severe mental illness, was jailed at Franklin County Corrections Center II for about one month and died on September 4, 2011 from congestive heart failure.
- Peterson did not disclose a prior diagnosis of congestive heart failure to jail medical staff; he received psychiatric care while detained and was seen by medical personnel as late as September 2, 2011.
- Inmates adjacent to Peterson reported hearing him moaning and struggling to breathe around 3:30–4:30 AM on the night he died; two deputies (Nibert and Hoar) encountered Peterson later that morning and stated he did not appear to need medical attention.
- Photographs and an internal affairs report showed Peterson’s cell was unsanitary at times; the report recommended discipline for many deputies for failures related to observation, logging, and cell maintenance.
- Plaintiffs sued 53 jail officials under 42 U.S.C. § 1983 (Fourteenth Amendment claims, treated as Eighth Amendment–type claims for detainees) and Ohio wrongful-death and related state claims. The district court granted summary judgment to all defendants except Deputies Nibert and Hoar.
- On appeal, the Sixth Circuit reversed the denial of summary judgment as to Nibert and Hoar (qualified immunity and Ohio statutory immunity) and affirmed summary judgment for all other defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to provide medical care (deliberate indifference) | Defendants ignored obvious signs of congestive heart failure and denied life-saving care | No evidence any nonmedical defendant was subjectively aware of a serious risk; they relied on medical staff and their own observations | No constitutional violation: plaintiffs failed to show each defendant had subjective knowledge and drew the inference of substantial risk; qualified immunity applies |
| Conditions of confinement (unsanitary cell) | Filthy cell and lack of mattress amount to inhumane conditions per Farmer/Rice | Conditions were not sufficiently serious or prolonged to violate clearly established law; some cleanings occurred | No clearly established violation for the period at issue; qualified immunity affirmed |
| Ministerial vs. discretionary duties (use to deny immunity) | Deputies performed ministerial duties (e.g., follow policies to check inmates), so immunity should not apply | Federal § 1983 claims are governed by federal law; Kentucky ministerial/discretionary doctrine inapplicable | Ministerial-duty argument rejected as inapplicable to federal claims; insufficient under Sixth Circuit precedent |
| Municipal liability / failure to train (Monell) | County failed to train/maintain policy leading to death; history of prior disciplinary incidents shows pattern | Prior incidents do not show a pattern of similar constitutional violations or deliberate indifference required by Connick | No municipal liability: plaintiffs failed to show deliberate indifference or a pattern sufficient to constitute official policy |
Key Cases Cited
- Bell v. Wolfish, 441 U.S. 520 (1979) (pretrial detainees’ protections derive from Due Process but encompass Eighth Amendment standards)
- Farmer v. Brennan, 511 U.S. 825 (1994) (objective/subjective deliberate indifference framework for conditions and medical care)
- Estelle v. Gamble, 429 U.S. 97 (1976) (constitutional right to adequate medical care for prisoners)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity two-step; courts may decide order of steps)
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability requires action pursuant to official policy)
- Connick v. Thompson, 563 U.S. 51 (2011) (failure-to-train claims require deliberate indifference and usually a pattern of violations)
- West v. Atkins, 487 U.S. 42 (1988) (contracted medical providers acting under color of state law can be sued under § 1983)
- Comstock v. McCrary, 273 F.3d 693 (6th Cir. 2001) (deliberate indifference requires that the defendant actually drew the inference of substantial risk)