Sheri Trozzi v. Lake County, Ohio, 29 F.4th 745

Sheri Trozzi, detained at Lake County Adult Detention Center, had prior gastric bypass and was prescribed antacids and a special diet to prevent ulcers.
Trozzi submitted requests for medications and diet adjustments and told a mental-health consultant she had ``issues with an ulcer;'' a nurse (Diane Snow) scheduled a doctor visit.
In the predawn hours before that visit Trozzi complained of severe abdominal pain; Corrections Officer Ryan Stakich summoned supervisor Scott Capron, who checked vitals (normal), gave OTC antacid, moved Trozzi to a medical holding cell, and called Snow by phone.
Snow advised monitoring every 30 minutes and did not call 911; Trozzi alleges Snow later berated her, refused to call 911, and left her covered in bodily fluids until the scheduled doctor visit the next day.
The jail doctor sent Trozzi to the hospital the next day where she had surgery for a perforated ulcer; Trozzi sued Stakich, Capron, and Snow under 42 U.S.C. § 1983 for deliberate indifference; the district court granted summary judgment for defendants and Trozzi appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Stakich was deliberately indifferent by not calling 911 after Trozzi complained of stomach pain	Trozzi: Stakich failed to summon emergency care despite her severe pain	Stakich: he promptly alerted supervisor, transported Trozzi, and relied on supervisor/vitals; lacked authority to call 911	Not liable — no evidence Stakich knew his inaction posed unjustifiably high risk; at most negligence
Whether Capron was deliberately indifferent by not calling 911 after assessing Trozzi	Trozzi: Capron saw Trozzi doubled over and failed to obtain emergency care	Capron: he took vitals (normal), gave antacid, placed Trozzi under observation, and followed nurse Snow's advice	Not liable — reasonable officer in his position would rely on medical professional and vitals; no evidence he knew failure to call 911 created excessive risk
Whether Snow was deliberately indifferent by advising monitoring and not calling 911	Trozzi: as the medical professional Snow knew Trozzi’s ulcer history and ignored obvious severe symptoms	Snow: she observed normal vitals, provided antacid, scheduled doctor, and reasonably monitored; she did not observe objective emergency signs	Court avoids deciding constitutional violation and holds Snow entitled to qualified immunity — Dominguez (facts distinguishable) did not clearly establish unlawfulness

Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate indifference to serious medical needs framework)
Farmer v. Brennan, 511 U.S. 825 (1994) (subjective deliberate-indifference standard requiring actual knowledge of excessive risk)
Kingsley v. Hendrickson, 576 U.S. 389 (2015) (objective unreasonableness inquiry for pretrial-detainee claims; two separate state-of-mind questions)
Brawner v. Scott County, 14 F.4th 585 (6th Cir. 2021) (modifies the subjective prong for pretrial-detainee medical claims; introduces reasonable-officer/Reckless-failure-to-mitigate language)
Greene v. Crawford County, 22 F.4th 593 (6th Cir. 2022) (applies Brawner: two-part inquiry considering what the officer knew and whether officer understood risks of inaction)
Dominguez v. Corr. Med. Servs., 555 F.3d 543 (6th Cir. 2009) (nurse denied summary judgment where evidence showed repeated calls, objective deterioration, and no meaningful care)
Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity framework permitting courts to resolve either constitutional violation or clearly-established-law prong)
Brosseau v. Haugen, 543 U.S. 194 (2004) (clearly established law requires fair notice to a reasonable official)