Schoelch v. Mitchell, 2010 U.S. App. LEXIS 23416

Schoelch, a pretrial detainee, was housed in unit 6B with Lindsey, a violent inmate.
Lindsey had a history of aggressive incidents and requests to be allowed into other inmates’ cells.
On Oct 27, 2004, Mitchell placed Schoelch on lockdown for infractions; Lindsey helped clean up and later allegedly prompted opening of Schoelch’s cell.
On Nov 12, 2004, Lindsey attacked Schoelch during lunch after entering his cell; Mitchell observed but did not intervene.
Schoelch sustained facial fractures and dental loss; Mitchell was fired after internal investigation; Schoelch sued Mitchell, supervisors, and St. Louis County for failure to protect and related claims; district court granted summary judgment, which this court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mitchell’s handling violated due process by failing to protect	Schoelch argues Mitchell’s action created substantial risk of harm.	Mitchell’s actions do not show deliberate indifference and no objective injury proven.	No constitutional violation; lacked objective injury and deliberate indifference not shown.
Whether the November 12 incident supports a claim of deliberate indifference	Schoelch contends Mitchell was deliberately indifferent to a known risk.	Evidence shows no notice of a substantial risk and attack was sudden.	Insufficient evidence of deliberate indifference; claim fails.
Whether supervisors and county can be liable for failure to train/supervise	Schoelch asserts known deficiencies in Mitchell’s training.	Record shows Mitchell was trained and the earlier incidents did not require segregation.	No basis for supervisory or municipal liability; district court correct.
Whether the case supports municipal liability absent a constitutional violation	St. Louis County liable due to policies allowing Lindsey in direct supervision unit.	No officer-level constitutional violation proven; no policy-based liability.	Municipal liability fails without a predicate constitutional violation.

Farmer v. Brennan, 511 U.S. 825 (1994) (required standard for deliberate indifference in confinement)
Kahle v. Leonard, 477 F.3d 544 (8th Cir. 2007) (due process standard for custodians of pretrial detainees)
Wilson v. Seiter, 501 U.S. 294 (1991) (conditions-of-confinement standard for constitutional violations)
Hudson v. McMillian, 503 U.S. 1 (1992) (objective harm standard in confinement claims)
Norman v. Schuetzle, 585 F.3d 1097 (8th Cir. 2009) (relevance of training/supervision in official liability)
Irving v. Dormire, 519 F.3d 441 (8th Cir. 2008) (requires objectively serious harm to sustain due-process claim)
Helling v. McKinney, 509 U.S. 25 (1993) (risk of future harm in Eighth Amendment analysis)