United States District Court, N.D. Ohio
OPINION & ORDER [RESOLVING DOCS. NOS. 47, 49,
S. GWIN, UNITED STATES DISTRICT JUDGE
Adam Bartlett brings this civil rights action against the
MetroHealth Defendants and the Cuyahoga County
Defendants and complains regards Defendants'
jailhouse treatment of his withdrawal symptoms. Defendants
have moved for summary judgment. Plaintiff has not opposed.
following reasons, the Court GRANTS both
parties' motions for summary judgment.
September 7, 2016, Plaintiff Bartlett was arrested for
violating his probation and was brought to the Cuyahoga
County Correctional Center. Because he was unprepared to be
arrested, Plaintiff alleges he did not take his prescribed
Xanax medication with him. Plaintiff alleges he also suffers from
alcohol and opioid abuse.
September 8, 2016 and September 14, 2016, the MetroHealth
Defendants allegedly failed to adequately assess and treat
Plaintiff for his withdrawal symptoms. 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.
brings claims under Section 1983 against all Defendants for
Fourth, Eighth, and Fourteenth Amendment
violations. 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.
MetroHealth Defendants and the County Defendants move for
summary judgment. The deadline for filing an opposition
has passed, and Plaintiff has not filed any opposition.
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.” 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.”
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. 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
Section 1983 Claims
Court grants summary judgment for the County Defendants and
MetroHealth Defendants on Plaintiff's Section 1983
Official Capacity Claims
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.
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.” Therefore, Plaintiff's official
capacity claims under Section 1983 are claims directly
against the County and the MetroHealth System.
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.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.
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.
Individual Capacity Claims
a. Qualified Immunity
MetroHealth Defendants and County Defendants sued in their
individual capacities are entitled to qualified immunity.
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.” Second, plaintiffs must prove that the
violated constitutional right was “clearly
established.” Courts do not have to decide these
prongs in a specific order.
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.
Court finds no genuine dispute of material fact as to
Plaintiff's Section 1983 individual capacity claims
against the County Defendants.
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. Plaintiff also alleges that the
individual County Defendants' action used excessive
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 ...