Crawford v. Tilley, No. 20-6391 (6th Cir. 2021)
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Marc was arrested and taken to the Madison County Detention Center (MCDC). Marc’s wife, Dawn, told the police that her husband had lung cancer and needed immediate medical attention. Marc’s medical records also stated that he had a blood clot in his leg. Dawn alleges that medical staff removed his pain medication patch, placed him on “inappropriate” psychoactive medications, and failed to provide him with his prescriptions. The medical contractor, Correct Care, refused to honor Marc’s scheduled chemotherapy appointments. Marc was transferred to Kentucky State Reformatory (KSR). He arrived with an elevated heart rate, difficulty breathing, and swelling in his leg. Staff withheld his prescribed medication, breathing treatments, and chemotherapy. Marc died less than a month after his arrest. His family was informed two days later. The autopsy revealed fluid accumulated in his lungs. Medical staff would have discovered this fluid if they had administered his prescribed breathing treatments.
Dawn’s 42 U.S.C. 1983 Eighth Amendment complaint alleged supervisory liability against Erwin, Acting Commissioner of the Kentucky Department of Corrections, claiming that Erwin “accepted” Marc’s transfer into KSR and “would have been made aware of [Marc’s] medical conditions” and had promulgated and maintained some of KSR’s allegedly unconstitutional policies. Dawn alleged that Erwin was “specifically aware that Correct Care” had a pattern of failing to provide inmates with adequate health care. The Sixth Circuit ordered the dismissal of the claims against Erwin. Dawn's complaint did not allege any “active unconstitutional behavior” by Erwin nor explain how his behavior proximately caused Marc’s injuries; Erwin is entitled to qualified immunity.
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