Claims arising from a pretrial detainee’s suicide; 42 USC § 1983; Watkins v. City of Battle Creek; “Deliberate indifference” to serious medical needs; U.S. Const. amends. VIII & XIV; Linden v. Washtenaw Cnty. (Unpub. 6th Cir.); Estelle v. Gamble; Psychological needs; Horn v. Madison Cnty. Fiscal Court; Comstock v. McCrary; The objective component; Farmer v. Brennan; Miller v. Calhoun Cnty.; Perez v. Oakland Cnty.; The subjective component; Downard for Estate of Downard v. Martin; Gray v. City of Detroit; Galloway v. Anuszkiewicz (Unpub. 6th Cir.); Grabow v. County of Macomb (Unpub. 6th Cir.); Nallani v. Wayne Cnty. (Unpub. 6th Cir.); Effect of a prior suicide attempt while in jail; Collins v. Seeman (7th Cir.); Effect of a defendant’s failure to follow jail policy; Bonner-Turner v. City of Ecorse (Unpub. 6th Cir.); A supervisor’s liability; Winkler v. Madison Cnty.; Bellamy v. Bradley; Taylor v. Michigan Dep’t of Corr.; Gregory v. City of Louisville; A municipality’s liability; Gregory v. Shelby Cnty.; Monell v. Department of Soc. Servs.; City of Canton v. Harris; Molton v. City of Cleveland; Crocker ex rel. Estate of Tarzwell v. County of Macomb (Unpub. 6th Cir.)

The court held that defendant-Cox, the jail classification officer, was improperly granted summary judgment on plaintiff’s claim of deliberate indifference to her father’s (Troutman) serious medical needs where Cox was aware of Troutman’s prior suicide attempt but still moved him to a barred single cell without obtaining the required medical clearance. But it affirmed summary judgment for defendants-jail director (Bolton) and municipality (Louisville Metro). Troutman, a pretrial detainee, committed suicide after being placed in solitary confinement despite a prior suicide attempt in his holding cell. Plaintiff sued under § 1983 for deliberate indifference to Troutman’s serious medical needs. Records from his incarceration indicated that jail personnel were aware that he had attempted suicide in his holding cell, had attempted suicide previously, had suffered a traumatic brain injury the year before, and exhibited other suicide risk factors. After an initial clearance from medical, he was moved into the general population. But Cox placed him into a single cell after altercations with other prisoners without first obtaining medical clearance, as required. He “agreed that placing an inmate with a bedsheet in a barred solitary cell presented an opportunity for a suicidal inmate to commit suicide.” The court concluded that his “failure to follow the jail policy of waiting to receive clearance from medical may itself be considered as circumstantial evidence of Cox’s subjective knowledge.” It held that there was sufficient evidence to bring plaintiff’s claims against Cox to the jury, which can decide if, as Cox argued, he was entitled to rely on a previous medical assessment that permitted Troutman’s placement “anywhere in the jail.” But as to Bolton, the court found plaintiff’s claims that he “inadequately performed his responsibilities—for instance, by failing to put in writing the policy of requiring medical clearance before transfer to solitary—” were insufficient for § 1983 supervisory liability. As to plaintiff’s claim that Louisville Metro’s “policies and procedures were the moving force behind the denial of adequate medical care to” Troutman, the court found that Louisville Metro had policies in place, and negligence as to how they were carried out was insufficient to support liability.