Troutman v. Louisville Metropolitan Department of Corrections, No. 20-5290 (6th Cir. 2020)Annotate this Case
Troutman, a daily user of heroin and methamphetamine, committed suicide in pretrial detention after LMDC jail officials placed him in solitary confinement despite a recent suicide attempt while in LMDC custody. A medical screening had indicated signs of depression; he had attempted suicide three to four times in the past and was “currently thinking about suicide.” Troutman had experienced a traumatic brain injury the prior year which left him in a coma for nine days, He told medical staff “I’m not good at all, I’m dying!”
In an action under 42 U.S.C. 1983, alleging deliberate indifference to his serious medical needs, the Sixth Circuit reversed summary judgment in favor of Cox, the LMDC classification officer, but affirmed summary judgment in favor of LMDC director Bolton and Louisville-Jefferson County Metro Government.
Troutman objectively “exhibited suicidal tendencies” and other risk factors. A reasonable jury could find that Cox was subjectively aware of the substantial risk if Troutman was placed in solitary confinement. Cox’s argument that he reasonably relied on the medical judgment that Charles no longer presented a suicide risk does not make summary judgment appropriate. Claims that Bolton inadequately performed his duties are insufficient for section 1983 supervisory liability. It is plausible that the municipality was negligent in enforcing its policies, but deliberate indifference remains distinct from mere negligence.