Anita Arrington-Bey v. City of Bedford Heights
2017 FED App. 0112P, 858 F.3d 988, 2017 U.S. App. LEXIS 9207 (2017)
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Rule of Law:
Government officials are entitled to qualified immunity from civil liability unless their conduct violates a constitutional right that was 'clearly established' at the time of the incident, which requires a plaintiff to identify precedent with a highly similar fact pattern. A municipality cannot be held liable for failure to train under a theory of deliberate indifference if the underlying constitutional right was not clearly established.
Facts:
- On June 21, 2013, Omar Arrington-Bey, who had recently been fired, went to a Lowe's store to pick up his last paycheck.
- While at the store, Arrington-Bey began speaking gibberish and then kicked and threw paint cans, prompting a 911 call.
- Officers Honsaker and Ellis stopped Arrington-Bey, who was a passenger in a car leaving the scene. During a pat-down, they found pills which Arrington-Bey stated were for a psychiatric condition.
- Arrington-Bey's mother, Anita, informed the officers that her son was bipolar, the pills were Seroquel, and he had not taken his medication for some time.
- Throughout the encounter, Arrington-Bey exhibited bizarre behavior, including ranting, making grandiose claims, and claiming his father was the son of Satan.
- At the Bedford Heights jail, Arrington-Bey continued his erratic behavior, which included performing a striptease, kicking doors, singing, making lewd gestures, and yelling racial slurs.
- Several hours after arriving at the jail, correctional officers let Arrington-Bey out of a room to make a phone call, at which point he, without warning, attacked and began choking one officer, and then a second officer who came to help.
- After officers subdued Arrington-Bey and placed him in a restraint chair, they noticed his pulse was weak. He was later pronounced dead at a hospital, with the autopsy citing a 'sudden cardiac event during a physical altercation in association with bipolar disease.'
Procedural Posture:
- Anita Arrington-Bey sued the individual officers and the City of Bedford Heights in federal district court, alleging violations of her son's federal and state rights.
- The defendants moved for summary judgment, asserting qualified immunity for the officers and no liability for the city.
- The district court denied qualified immunity to the officers and denied the City's motion for summary judgment on the Fourteenth Amendment claim.
- The individual officers and the City of Bedford Heights (appellants) appealed the district court's denials to the U.S. Court of Appeals for the Sixth Circuit.
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Issue:
Do police officers who arrest a mentally unstable individual and take him to jail, where he later dies of a sudden cardiac event following a physical altercation, violate a clearly established constitutional right to medical care, thereby forfeiting their qualified immunity?
Opinions:
Majority - Sutton, Circuit Judge
No. The officers did not violate a clearly established right and are therefore entitled to qualified immunity. The court reasoned that while pretrial detainees have a right to medical treatment for serious needs, this general principle is insufficient to overcome qualified immunity. A right is 'clearly established' only when existing precedent is so specific that it gives officers 'fair and clear warning' that their conduct is unlawful. The plaintiff failed to identify any Supreme Court or Sixth Circuit case with a similar fact pattern that would have required officers to take a delusional arrestee like Arrington-Bey to a hospital instead of a jail. Similarly, the jailers' actions—secluding him for safety and waiting until he was calm—did not violate any clearly established law, especially since the fatal heart attack was not a foreseeable risk. Because the individual officers' conduct did not violate a clearly established right, the City's 'failure to train' claim also fails, as a municipality cannot be deliberately indifferent to a constitutional duty that is not yet clear.
Analysis:
This decision reinforces the formidable barrier of the 'clearly established' prong of qualified immunity, emphasizing the Supreme Court's mandate that the law must be established with a high degree of specificity. By requiring a plaintiff to produce a case with nearly identical facts, the ruling makes it significantly more difficult to hold officers accountable in novel situations involving detainees with mental health issues. Furthermore, the court solidifies the link between individual officer immunity and municipal liability, holding that a city cannot be liable for a 'failure to train' on a constitutional duty that was not itself clearly established. This creates a circular logic that can shield both officers and their employers from liability, potentially stifling the development of constitutional law in this area.
