42 USC § 1983; Deliberate indifference to a pretrial detainee’s medical needs; Qualified immunity; Whether defendants-corrections officers “reasonably deferred” to medical staff who were treating the detainee; Grote v Kenton Cnty; Claim under Monell v Department of Soc Servs; Refusal to exercise supplemental jurisdiction over state-law claims

[This appeal was from the WD-MI.] The court affirmed summary judgment based on qualified immunity for defendants-jail corrections officers in this case involving claims of deliberate indifference to a pretrial detainee’s medical needs. It held that once medical professionals became involved in the detainee’s treatment, “the officers reasonably deferred to” them. Plaintiff-estate’s decedent, Joseph Hehrer, a detainee at the Clinton County jail, became ill. Medical “staff repeatedly evaluated him” but failed to discover “that he suffered from a previously undiagnosed condition: diabetes.” He was removed to a hospital, where he died from diabetes complications. At his first meeting with defendant-nurse, he denied having diabetes or any other medical conditions except a concussion. Plaintiff asserted deliberate indifference claims against several officers and a Monell claim against defendant-County for failure to adequately train them. It also brought several state-law claims against a company the County contracted with to provide medical care to inmates and company employees. The district court granted the County and its officers summary judgment and refused to exercise supplemental jurisdiction over the state-law claims. Treating Hehrer as a pretrial detainee under the Fourteenth Amendment, the court explained that “once inmates begin to receive care from a medical professional, officers typically act reasonably by following the ‘medical professional’s diagnosis or treatment.’” Although it noted that such deference “has its limits[,]” this case resembled “others in which we have held that corrections officers could ‘reasonably defer’ to the medical staff who were treating an inmate.” And the cases on which plaintiff relied did “not look anything like this one.” As to the Monell claim, the court concluded that even if it assumed plaintiff showed that the “County did not adequately train its officers, it has not established that the County acted with deliberate indifference.” Finally, the district court did not abuse its discretion by dismissing the state-law claims where this circuit’s “caselaw requires district courts to presume that they should decline [supplemental] jurisdiction if they have rejected all the federal claims before trial.”