Devereux v. Knox County, No. 19-6071 (6th Cir. 2021)
Annotate this Case
Devereux suffered a major stroke during or around the period of his custody by Knox County for misdemeanor first-time DUI. Corrections officers were in and out of the holding cell where he sat motionless for several hours but did not provide medical attention until it was too late to mitigate the stroke’s effects. Devereux brought federal civil rights claims and negligence claims under the Tennessee Governmental Tort Liability Act (TGTLA), which waives sovereign immunity for certain claims, but not those arising from “civil rights.”
The district court dismissed all of Devereux’s claims against the officers and his civil rights claims against Knox County. It declined to exercise supplemental jurisdiction over the TGTLA claims and dismissed them without prejudice, allowing Devereux to refile in state court. Knox County argued that the court should have retained jurisdiction and determined that the TGTLA’s “civil rights exception” necessarily barred Devereux’s negligence claims. The Sixth Circuit vacated in part. The best approach is to give Tennessee courts a fresh opportunity to consider whether the TGTLA claims ivolve civil rights. The court vacated “to prevent any issue of collateral estoppel in state court based on this aspect of the district court’s reasoning. The court declined to certify the issue to the Tennesse Supreme Court.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.