Samantha Burwell v. City of Lansing, Mich., 7f4th456

Background

Christopher Phillips was arrested for driving on a suspended license, booked into Lansing City Jail, and reported at booking that he had epilepsy and had taken pregabalin (Lyrica) that morning; he would need another dose that night.
Phillips was placed in general population; officers monitor detainees by video and half‑hour cell checks recorded via a card swipe; his name appeared on a “watch closely” board.
Video showed Phillips repeatedly sway, fall, rock, grab his head/abdomen, and ultimately collapse to the cell floor; vomit began pooling around his head about 45 minutes after collapse and increased over time; he remained motionless for hours and was later pronounced dead of multiple drug intoxication with aspirated gastric contents.
Multiple officers performed or logged cell checks but admitted failing to follow policy; internal investigation faulted two officers (Ouderkirk and Kelley) with counseling statements; no suspensions.
Phillips’s estate sued under 42 U.S.C. § 1983 (deliberate indifference), municipal liability for failure to train, and Michigan gross negligence; the district court granted summary judgment for all defendants; the Sixth Circuit affirmed in part and reversed as to Officer Brian Kelley only, and affirmed dismissal of the state gross‑negligence claim for failure to prove proximate cause.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers were deliberately indifferent to Phillips’s serious medical needs (subjective component)	Phillips’s estate: officers (esp. Kelley) actually observed obvious distress (unconscious in vomit) and thus had subjective knowledge and failed to act	Officers: they did not subjectively perceive a serious medical emergency; some only breached policy negligently	Only Kelley has sufficient record evidence for a jury to find subjective knowledge and deliberate indifference; summary judgment affirmed for the other officers
Whether Kingsley v. Hendrickson eliminated subjective intent for pretrial‑detainee deliberate indifference claims	Burwell: Kingsley’s objective standard extends to medical‑need claims so plaintiff need only show officers should have known	Defendants: traditional subjective standard applies; district court relied on it	Court declined to resolve extension of Kingsley (issue waived); applied traditional subjective test and required subjective awareness
Qualified immunity for Kelley	Burwell: Kelley violated clearly established right to not have known, serious medical needs disregarded	Kelley: entitled to qualified immunity because his conduct did not violate clearly established law	Court held the right was clearly established (failure to render aid to an unconscious detainee in vomit violated rights); reversed summary judgment as to Kelley (no qualified immunity at summary stage)
State‑law gross negligence and proximate cause	Burwell: officers’ gross negligence caused Phillips’s death	Defendants: proximate cause was Phillips’s voluntary ingestion of drugs; immunity applies	Affirmed: plaintiff failed to show officers’ gross negligence was the one most immediate, efficient, and direct cause of death; governmental immunity bars recovery

Key Cases Cited

Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment requires prison medical care)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard requires subjective knowledge of risk)
Kingsley v. Hendrickson, 576 U.S. 389 (2015) (pretrial‑detainee excessive‑force claims use objective standard)
Blackmore v. Kalamazoo County, 390 F.3d 890 (6th Cir. 2004) (objective/subjective framework for denial of medical care; vomiting as manifestation of internal disorder)
Comstock v. McCrary, 273 F.3d 693 (6th Cir. 2001) (elements of deliberate indifference and inference from circumstantial evidence)
Richmond v. Huq, 885 F.3d 928 (6th Cir. 2018) (discussing Kingsley’s implications for pretrial‑detainee claims)
Quigley v. Tuong Vinh Thai, 707 F.3d 675 (6th Cir. 2013) (qualified immunity and the clearly established right regarding known, serious medical needs)
Phillips v. Roane County, 534 F.3d 531 (6th Cir. 2008) (right to have medical assistance summoned when officers know detainee needs immediate care)
Rouster v. County of Saginaw, 749 F.3d 437 (6th Cir. 2014) (information available to one defendant not automatically imputed to others; obvious risk can give rise to knowledge)
Preyor v. City of Ferndale, [citation="248 F. App'x 636"] (6th Cir. 2007) (vomiting and lying on cell floor establish serious medical condition)