Nadine Keith, et al.v.Thomas E. Brown
After pretrial detainee Godfrey Cook was killed by another detainee at the DeKalb County Jail, Cook’s estate administrator and adult children sued Sheriff Thomas Brown, DeKalb County, and jail officers under federal and state law. They alleged, among other things, that Brown’s supervision, jail policies, and officer training failed to protect Cook. In this interlocutory appeal, Brown challenged only the denial of qualified immunity on the individual-capacity federal deliberate-indifference claim. The Eleventh Circuit held that the record did not show Brown’s subjective awareness of a substantial risk to Cook or a widespread pattern of violations that would give him notice. It also concluded that clearly established law did not require Brown to override mental-health professionals’ housing decisions, and that the earlier detainee death did not establish the necessary notice. The failure-to-train theory failed because the evidence did not show notice of a training deficiency, causation, or a violation of clearly established law. The court reversed the denial of summary judgment on that claim; the appeal did not resolve the other claims or the claims against the other defendants.
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