979 F.3d 472
6th Cir.2020Background
- Nov. 2015: Charles Troutman, arrested for drug offenses, attempted suicide in booking (gauze tightened around his neck); intake nurse documented prior attempts, current suicidal ideation, depression, substance use, and possible impaired cognition.
- Medical/mental-health staff cleared Troutman for general population on Nov. 17 after observation for detox and suicide risk.
- After two inmate altercations, Classification Officer James Cox moved Troutman to a barred solitary cell pending discipline on Nov. 24; Cox knew of the earlier in-jail suicide attempt and that he was "waiting to hear back from medical" about single-cell use but did not wait for confirmation.
- Less than two hours after placement in the barred single cell, Troutman hanged himself with a bedsheet and later died; family later settled with some medical defendants.
- Procedural posture: district court granted summary judgment for Cox, Warden Mark Bolton, and Louisville-Jefferson County Metro Government on § 1983 and related claims; Sixth Circuit reverses as to Cox (trialworthy issue), affirms as to Bolton and the municipality, and reinstates state-law claims relevant to Cox.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference by Cox for moving detainee with recent attempt into barred solitary cell without waiting for medical clearance | Cox knew of prior suicide attempt and risks of barred cells but ignored the need to get medical clearance before single-cell placement | Cox relied on prior medical clearance for general population and reasonably believed detainee was not suicidal | Reversed as to Cox: genuine dispute whether Cox subjectively knew of a strong likelihood of suicide and disregarded it by moving Troutman without confirmed medical clearance (jury issue) |
| Supervisor liability for Bolton (warden) | Bolton failed to ensure written policies, training, and to act on recommendations (e.g., remove bars), amounting to abdication of duties | Bolton did not personally abandon duties or implicitly authorize misconduct; any failures were inadequate performance, not abdication | Affirmed: plaintiff did not show Bolton personally abandoned duties or implicitly approved subordinate misconduct required for § 1983 supervisory liability |
| Municipal liability (Louisville Metro) under Monell for customs/policy failures and inadequate training | City policies/customs and pattern of jail suicides made the risk obvious; inadequate training and enforcement were moving force behind death | City had suicide-avoidance policies (including clearance and "no-bars" flags); evidence at most shows negligence in administration, not deliberate municipal conduct causing constitutional violation | Affirmed: no showing that municipality’s deliberate conduct was the moving force behind constitutional injury; negligence insufficient for Monell § 1983 liability |
| Supplemental jurisdiction over state-law wrongful-death/gross-negligence claims | State claims are relevant to revived federal claim against Cox and should be reinstated | District court properly declined jurisdiction after dismissing federal claims | Sixth Circuit reinstated state-law claims to the extent they are relevant to Cox because some federal claims against Cox survived |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (prisoners’ deliberate indifference to serious medical needs violates the Constitution)
- Farmer v. Brennan, 511 U.S. 825 (1994) (subjective deliberate indifference standard; knowledge may be inferred when risk is obvious)
- Kingsley v. Hendrickson, 576 U.S. 389 (2015) (discussed as potentially relevant standard for pretrial detainee claims)
- Perez v. Oakland Cty., 466 F.3d 416 (6th Cir. 2006) (moving detainee to single cell without medical input can raise genuine issue on deliberate indifference)
- Comstock v. McCrary, 273 F.3d 693 (6th Cir. 2001) (prison officials alerted to serious medical needs must provide care; psychological needs and suicide risk are serious needs)
- Downard for Estate of Downard v. Martin, 968 F.3d 594 (6th Cir. 2020) (explains "strong likelihood" standard for obvious suicide risk)
- Gray v. City of Detroit, 399 F.3d 612 (6th Cir. 2005) (municipal liability requires obvious risk and that municipality’s deliberate conduct was moving force)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipality liable under § 1983 only when policy or custom causes constitutional violation)
- City of Canton v. Harris, 489 U.S. 378 (1989) (inadequate training may be municipal liability only when deliberate indifference is shown)
- Molton v. City of Cleveland, 839 F.2d 240 (6th Cir. 1988) (negligence in policies/administration does not establish § 1983 municipal liability)