Theodore J. Thompson v. Michael A. Adkinson, 20-10642

Thompson, a pretrial detainee with long‑standing schizophrenia and bipolar disorder, was prescribed Seroquel, Trazodone, Prozac, and Neurontin while in custody.
Transferred to Walton County Jail, Thompson signed a form acknowledging a jail policy forbidding "cheeking" pills and stating that cheeking could lead to discontinuation of medication, but that medications for "life‑threatening" conditions would be continued by other means until a doctor saw the inmate.
A nurse, Kaci Tiller, accused Thompson of cheeking; the jail (with medical director Dr. Sheppard's approval) discontinued Seroquel, Trazodone, and Neurontin; Prozac continued but Thompson refused it.
After about 12 days off those medications, Thompson reported hallucinations and suicidal ideation, then attempted suicide by cutting his wrist; medications were restarted about a week later.
Thompson sued under 42 U.S.C. § 1983 alleging deliberate indifference and that jail employees acted pursuant to Sheriff Adkinson’s policy; the district court granted summary judgment to Adkinson (also citing failure to exhaust), and Thompson appealed.
The Eleventh Circuit reviewed de novo, framed the legal question as supervisory liability (causal connection between Adkinson’s policy and the denial of medication), and resolved the appeal on that ground.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sheriff Adkinson can be held supervisorially liable under § 1983—i.e., whether there is a causal connection between Adkinson's policy and the discontinuation of Thompson's medications	Thompson: Tiller discontinued meds pursuant to Adkinson’s "no‑cheeking" policy, so the policy caused the deprivation	Adkinson: The written policy expressly required continued provision of medication for life‑threatening conditions; evidence shows Tiller acted outside policy (personal vendetta), so no causal link	Held: No causal connection; policy’s exception required continued treatment for life‑threatening conditions, so supervisor liability fails; summary judgment affirmed
Whether Thompson failed to exhaust administrative remedies before suing	Thompson did not establish exhaustion	Adkinson argued Thompson failed to follow grievance procedures	Held: District court also granted summary judgment on exhaustion, but the Eleventh Circuit affirmed on lack of causal connection and did not decide exhaustion

Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for serious medical needs)
Hamm v. DeKalb Cnty., 774 F.2d 1567 (11th Cir. 1985) (Fourteenth Amendment deliberate indifference standard for pretrial detainees)
Goebert v. Lee Cnty., 510 F.3d 1312 (11th Cir. 2007) (elements for deliberate indifference claim, including causation)
Braddy v. Fla. Dep’t of Labor & Emp. Sec., 133 F.3d 797 (11th Cir. 1998) (supervisory liability requires causal connection or personal participation)
Douglas v. Yates, 535 F.3d 1316 (11th Cir. 2008) (ways to establish causal connection for supervisory liability)
Hartley v. Parnell, 193 F.3d 1263 (11th Cir. 1999) (no respondeat superior liability under § 1983)
Goodman v. Kimbrough, 718 F.3d 1325 (11th Cir. 2013) (affirming summary judgment where written policy forbade the unconstitutional conduct that caused injury)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard)
Smelter v. S. Home Care Servs., Inc., 904 F.3d 1276 (11th Cir. 2018) (de novo review of summary judgment and construing facts for non‑movant)