Estate of Hill v. Miracle, No. 16-1818 (6th Cir. 2017)Annotate this Case
Hill suffered a diabetic emergency. Paramedics, including Streeter, found Hill very disoriented and combative. Streeter tested Hill’s blood-sugar level, which was extremely low at 38. As blood sugar falls, a person may lose consciousness, become combative and confused, or suffer a seizure. A blood-sugar level of 38 is a medical emergency and, untreated, can lead to death. Deputy Miracle arrived as paramedics were attempting to intravenously administer dextrose to raise Hill’s blood-sugar level. Hill ripped the catheter from his arm, causing blood to spray, and continued to kick, swing, and swear as the paramedics tried to restrain him. Miracle eventually deployed his taser to Hill’s thigh, quieting Hill long enough for Streeter to reestablish the IV catheter and administer dextrose. Hill’s blood-sugar levels stabilized. Hill denied being in pain, but was taken to the hospital. Not treatment was rendered for the taser wound. Hill claimed that he suffered burns and that his diabetes worsened. Hill filed suit under 42 U.S.C. 1983, alleging excessive force, with state-law claims of assault and battery and intentional infliction of emotional distress. Hill subsequently died from complications of diabetes. The district court denied Miracle’s claim of qualified immunity. The Sixth Circuit reversed, with instructions to dismiss. Miracle acted in an objectively reasonable manner with the minimum force necessary to bring Hill under control, and his actions enabled the paramedics to save Hill’s life.