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Bartlett v. Cuyahoga County

United States District Court, N.D. Ohio

May 22, 2018

CUYAHOGA COUNTY, et al., Defendants.

          OPINION & ORDER [RESOLVING DOCS. NOS. 47, 49, 50]


         Plaintiff Adam Bartlett brings this civil rights action against the MetroHealth Defendants[1] and the Cuyahoga County Defendants[2] and complains regards Defendants' jailhouse treatment of his withdrawal symptoms. Defendants have moved for summary judgment.[3] Plaintiff has not opposed.

         For the following reasons, the Court GRANTS both parties' motions for summary judgment.[4]

         I. BACKGROUND[5]

         On September 7, 2016, Plaintiff Bartlett was arrested for violating his probation and was brought to the Cuyahoga County Correctional Center.[6] Because he was unprepared to be arrested, Plaintiff alleges he did not take his prescribed Xanax medication with him.[7] Plaintiff alleges he also suffers from alcohol and opioid abuse.[8]

         Between September 8, 2016 and September 14, 2016, the MetroHealth Defendants allegedly failed to adequately assess and treat Plaintiff for his withdrawal symptoms.[9] On September 13, 2016, County Defendants Mirrotto, Bailey, and Cartwright allegedly improperly forced Plaintiff Bartlett into a restraint chair after Bartlett defecated and urinated on his cell floor during withdrawal.[10]

         Plaintiff brings claims under Section 1983 against all Defendants for Fourth, Eighth, and Fourteenth Amendment violations.[11] Plaintiff also brings the state law claims for intentional infliction of emotional distress claims against all Defendants; a medical malpractice claim against Dr. Tallman and Dr. Koblentz; negligence claims against all individual MetroHealth Defendants; and a battery claim against all individual County Defendants.[12]

         The MetroHealth Defendants and the County Defendants move for summary judgment.[13] The deadline for filing an opposition has passed, and Plaintiff has not filed any opposition.


         A party is entitled to summary judgment “if the pleadings, depositions, answers to the interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.”[14] The moving party bears an initial burden of pointing to facts in the record that entitle it to summary judgment. Once the moving party has met this burden, the non-moving party “must set forth specific facts showing there is a genuine issue for trial.”[15]

         If a motion for summary judgment goes unopposed, a reviewing court is not required to “conduct its own probing investigation of the record” and may properly rely on the facts provided by the moving party.[16] A court is only required to “intelligently and carefully review the legitimacy of such an unresponded-to motion” in order to determine whether the movant has met their initial burden.[17]

         III. ANALYSIS

         A. Section 1983 Claims

         The Court grants summary judgment for the County Defendants and MetroHealth Defendants on Plaintiff's Section 1983 claims.

         1. Official Capacity Claims

         To bring a Section 1983 official capacity suit, Plaintiff must demonstrate a direct link between a governmental policy or custom and a constitutional deprivation by showing that the alleged injury was caused by the execution of a particular policy or custom.[18]

         A suit against a government employee in his or her official capacity “represent[s] only another way of pleading an action against an entity of which an officer is an agent.”[19] Therefore, Plaintiff's official capacity claims under Section 1983 are claims directly against the County and the MetroHealth System.

         Plaintiff Bartlett has alleged that the County and MetroHealth Defendants failed to institute adequate policies, procedures, customs, usages and protocols on identification, referral, and treatment for inmates experiencing withdrawal, and failed to train and supervise staff accordingly.[20]Plaintiff alleges that such failure caused the County Defendants to punitively place him in the restraint chair and cause his injuries, and the MetroHealth Defendants to inadequately assess and treat his withdrawal.[21]

         However, there is no evidence to support Plaintiff's allegations, and Plaintiff has brought forth no evidence on the matter. There is thus no genuine material factual dispute on Plaintiff's Section 1983 official capacity claims against the County Defendants and MetroHealth Defendants. The Court GRANTS summary judgment for Defendants on Plaintiff's Section 1983 official capacity claims.

         2. Individual Capacity Claims

          a. Qualified Immunity

         The MetroHealth Defendants and County Defendants sued in their individual capacities are entitled to qualified immunity.

         Government officers are entitled to qualified immunity for their actions unless plaintiffs satisfy a two-prong test. First, plaintiffs must show that “the facts alleged show the officer's conduct violated a constitutional right.”[22] Second, plaintiffs must prove that the violated constitutional right was “clearly established.”[23] Courts do not have to decide these prongs in a specific order.[24]

         There is no genuine dispute of material fact as to the first prong. As will be explained, no jury could find that the individual MetroHealth and County Defendants violated Plaintiff's constitutional rights. The Court finds the individual Defendants are entitled to qualified immunity.

         b. County Defendants

          The Court finds no genuine dispute of material fact as to Plaintiff's Section 1983 individual capacity claims against the County Defendants.

         Plaintiff alleges that the individual County Defendants were deliberately indifferent to his serious medical need when they punitively forced him into a restraint chair upon discovering he was suffering from severe withdrawal symptoms.[25] Plaintiff also alleges that the individual County Defendants' action used excessive force.[26]

         “The Eighth Amendment's protections against cruel and unusual punishment extend to pretrial detainees through the Fourteenth Amendment's Due Process Clause . . . and thus claims by pretrial detainees challenging conditions ...

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