Downard v. Martin, No. 20-3046 (6th Cir. 2020)
Annotate this Case
After almost 20 years as a Reynoldsburg detective, Tye was charged with a federal drug trafficking offense. While awaiting a preliminary hearing, Tye committed suicide in his cell at the Delaware County Jail. In a suit under 42 U.S.C. 1983 for deliberate indifference to Tye’s serious medical need, with state-law claims for wrongful death and survival, the district court denied summary judgment to officers Foley and Wallace, finding that neither was entitled to federal qualified immunity or immunity under Ohio law.
The Sixth Circuit reversed. The facts and inferences as found by the district court do not, as a matter of law, show that either officer was aware that Tye posed a “strong likelihood” of attempting suicide. During the intake process, Tye denied any thoughts of suicide, feelings of hopelessness, or history of psychiatric issues. Foley reported no visible signs of distress, noting only that Tye was a “peace officer.” Tye was later seen by a nurse, who ministered her own physical and mental health assessments, and again denied any thoughts of suicide, feelings of hopelessness, or history of psychiatric issues. Tye later met with a mental health clinician, who reported only “[n]ormal [f]inding[s]” with respect to demeanor, mood, thought process, behavior, affect, and cognition.
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.