Grote v. Kenton County, Kentucky, No. 23-5133 (6th Cir. 2023)
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During his booking at Kenton County Detention Center, Grote could not complete paperwork while standing nor be photographed due to his agitated state. By the time he was examined by LPN Brand, Grote was constantly shaking and twitching and was covered in sweat. With officers, Grote denied that he had taken any substances but told Brand that he had taken a half gram of methamphetamine. Grote’s oxygen level was 89 percent; he was hyperventilating. Brand was unable to take any other vital signs. Brand does not recall communicating to anyone her assessment that Grote was detoxing. Deputies conducted sporadic checks on Grote in his cell before an inmate reported that Grote was unconscious and foaming at the mouth. Grote suffered multiple cardiac arrests and did not regain neurological function before dying. A doctor testified that Grote’s overdose would have been obvious to a layperson and that the situation required urgent medical care. Grote had a blood methamphetamine concentration 14 times higher than “the lowest reported lethal dose.”
The KCDC defendants testified received no training on recognizing signs of an overdose or detox and could not call 911 immediately in the event of an inmate overdose, but instead were to notify shift managers. The Sixth Circuit reversed, in part, the dismissal of a section 1983 suit. A jury could find that the medical provider was deliberately indifferent to Grote’s need for medical attention, but not that the deputies acted unconstitutionally.
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