Moderwell v. Cuyahoga County, No. 20-3879 (6th Cir. 2021)
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Cuyahoga County planned for CCCC to house detainees and prisoners from nearby communities in exchange for significant payments. CCCC was already severely overcrowded and understaffed. In March 2018, Cleveland transferred inmates to CCCC. In May, the County Council agreed that CCCC’s issues were “mission-critical” but no action was taken.
On June 20, 2018, Johnson was detained at CCCC, awaiting trial for petty theft. During intake, a nurse noted that he was “likely a suicide risk" having previously attempted self-harm. No protective action was taken. Days later, Johnson told a nurse that he was “suicidal.” No action was taken. CCCC correctional officers were aware that Johnson was a suicide risk. On June 29, Officers placed Johnson in solitary confinement for allegedly trying to steal food; no one checked on him. That evening, Johnson was found hanging in the cell. CCCC lacked a device for cutting him down. On July 1, Johnson died.
The Department of Justice reviewed and reported CCCC's “appalling conditions,” including medical staff lacking proper licenses, mental health appraisals not being conducted in a timely manner, and deliberate use of food deprivation as punishment. CCCC housed 2,420 individuals; its capacity was 1,765. There were 96 correctional officer vacancies.
Moderwell sued corrections officers and executives under 42 U.S.C. 1983. The district court granted the defendants judgment on Eighth Amendment claims and dismissed an excessive force claim against the executives but concluded that the complaint sufficiently alleged excessive force against the officers and deliberate indifference to serious medical needs against the executives. The Sixth Circuit affirmed. Plaintiff’s deliberate indifference claims against the officers rely on the same facts as the excessive force claims, so denying qualified immunity did not impose additional discovery burdens. Whether precedent clearly established a right that was violated by the executives requires factual development.
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