Sallenger v. City of Springfield, Ill.
2010 U.S. App. LEXIS 25803
| 7th Cir. | 2010Background
- Andrew Sallenger, a 35-year-old with bipolar disorder and schizophrenia, experienced a psychotic episode at his mother's Springfield, Illinois home.
- Three Springfield police officers restrained Sallenger with a hobble after a violent struggle and subduing him.
- Minutes after hobbling, Sallenger stopped breathing; officers removed the hobble, performed CPR, and called an ambulance, but Sallenger died.
- Estate sue 3 officers and City for Fourth Amendment medical-care violations and Monell claim for failure to train in hobble use; district court granted summary judgment on both.
- Jury later found no liability for excessive-force claims; Monell claim depended on underlying constitutional violation, which did not occur here.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the medical-care response reasonable under the Fourth Amendment? | Estate argues seven-minute delay before aid began. | Officers reacted promptly after realizing unresponsiveness; no unreasonable delay. | Yes; officers' response was reasonable; grant of summary judgment affirmed. |
| Can City be liable under Monell for failure to train in hobble use absent a constitutional violation? | City's training deficiency caused violation through officer conduct. | No Monell liability without underlying constitutional violation. | No Monell liability; underlying Fourth Amendment violation did not occur; City not liable. |
Key Cases Cited
- Cant o n v. Harris, 489 U.S. 378 (1989) (Monell liability for failure to train requires a constitutional violation by an officer)
- Lopez v. City of Chicago, 464 F.3d 711 (7th Cir. 2006) ( Fourth Amendment medical-care standard at time of arrest)
- Williams v. Rodriguez, 509 F.3d 392 (7th Cir. 2007) (four-factor test for medical-care adequacy during detention)
- Sides v. City of Champaign, 496 F.3d 820 (7th Cir. 2007) (Fourth Amendment medical-care standard during detention)
- Jenkins v. Bartlett, 487 F.3d 482 (7th Cir. 2007) (Monell liability requires underlying constitutional violation)
- Teague v. Mayo, 553 F.3d 1068 (7th Cir. 2009) (jurisdictional principles applying jury verdicts as law of the case)
- King v. E. St. Louis Sch. Dist., 496 F.3d 812 (7th Cir. 2007) (summary-judgment standard in evaluating qualified-immunity related issues)
- Hildebrandt v. Ill. Dep't of Natural Res., 347 F.3d 1014 (7th Cir. 2003) (limitations on evaluating evidence presented after summary judgment)