Hyman v. Lewis, No. 21-2607 (6th Cir. 2022)Annotate this Case
At the Detroit Detention Center, officers searched Lipford and did not find any contraband. Lipford denied being under the influence of drugs or carrying any medication. At 9:48 p.m., officers placed Lipford in a glass-walled room used to hold multiple detainees awaiting arraignment. Lipford nodded off. He slid to the floor at 11:02 p.m. Lipford laid on the floor motionless until 2:50 a.m. when he was found unresponsive. He was pronounced dead at 3:50 a.m. Hospital staff found cocaine, heroin, and fentanyl, concealed in Lipford’s rectum. The jail’s operating procedures required that officers conduct rounds every 30 minutes; “physically open the cell doors" and ensure that detainees are actually there; and check "that every detainee is living and breathing.” Although Officer Lewis ostensibly made his rounds that night, he did not physically enter the video-arraignment room nor speak with the detainees. Avoiding interaction with detainees was apparently common because detainees would become agitated at officers waking them up.
The district court dismissed claims by Lipford’s estate against several defendants. The Sixth Circuit affirmed summary judgment in favor of Lewis. The estate did not establish that a reasonable officer in Lewis’s position would have known that Lipford was potentially concealing drugs, subjecting himself to an excessive risk of harm, and that Lewis’s ignoring this risk was objectively reckless. Failure to follow internal policies does not, alone, equal deliberate indifference.