Westmoreland v. Butler County, No. 21-5168 (6th Cir. 2022)
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Butler County Jail (BCJ) booked Westmoreland on a bench warrant for failure to appear. Westmoreland requested to be separated from fellow inmate St. Clair because St. Clair believed Westmoreland was an informant. Westmoreland was assigned to a general population dormitory with six cellmates that did not share a common area with St. Clair. Westmoreland’s mother called to express concerns that St. Clair was telling other inmates Westmoreland had “told on him.” The next day, St. Clair was permitted to mop floors outside of Westmoreland’s cell and allegedly told Westmoreland’s cellmates that he was a “rat.” Westmoreland's subsequent request to be moved was denied. That night, other inmates attacked Westmoreland, who required two surgeries for his injuries; his jaw was wired shut for several months. The district court rejected Westmoreland’s claims under 42 U.S.C. 1983.
The Sixth Circuit vacated, holding that the district court applied the wrong standard in evaluating the liability of an individual jail supervisor. A failure-to-protect claim by a pretrial detainee requires only an objective showing that an individual defendant acted (or failed to act) deliberately and recklessly. Whether BCJ is liable for that officer’s actions is contingent on whether a constitutional violation occurred.
The court issued a subsequent related opinion or order on June 2, 2022.
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