Burwell v. City of Lansing, No. 20-1505 (6th Cir. 2021)
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Phillips, then 39, was arrested for driving with a suspended license. At the Lansing City Jail, Phillips said he took Lyrica to treat his epilepsy and would need another dose that night Phillips denied being under the influence of other drugs or alcohol but was sweating. Phillips was taken to his cell at 2:15 p.m. Detainees are monitored through video cameras and cell checks, which involve a “physical inspection” of the cell. Video footage shows Phillips swaying, falling, and struggling. A pool of vomit formed around Phillips’s head at 3:23 p.m. No further movement was detected after 3:46 p.m. Several cell checks were recorded but officers did not follow department policy. At 5:11 p.m., when an officer entered his cell, Phillips was unresponsive, EMS transported Phillips to a hospital where he was officially pronounced dead at 5:44 p.m., most likely of “multiple drug intoxication,” having ingested oxycodone, alprazolam, and pregabalin.
The district court dismissed a suit under 42 U.S.C. 1983 that alleged deliberate indifference to Phillips’s medical needs and failure to train officers, and gross negligence under Michigan law. The Sixth Circuit affirmed in part. There was insufficient evidence from which to infer that any of the defendants subjectively perceived Phillips was suffering from a serious medical need, inferred he needed treatment, or ignored his medical needs. The court reversed as to one officer, who had the requisite state of mind for liability.
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