42 USC § 1983; Pretrial detainee’s drug overdose death in jail; Municipal liability; Monell v Department of Soc Servs; Failure to train claim; Adequacy of the training program; Helphenstine v Lewis Cnty; Distinguishing Linden v City of Southfield & Wright v Louisville Metro Gov’t; Deliberate indifference element; Board of Cnty Comm’rs of Bryan Cnty v Brown; “Obviousness”; Causation; Failure to medically screen claim; Requirement that plaintiff allege the existence of a clear & persistent pattern of unconstitutional conduct; Claim based on a municipal custom of jail overcrowding; Failure to sufficiently allege a causal link; Claim based on a municipal policy of jail underfunding; Unlawful action requirement

The court held that plaintiff stated a plausible claim against defendant-County for failure to train related to her father’s (Lewis) drug overdose death while in pretrial detention. But it concluded that she did not plausibly state her claims “that the County maintained policies of inadequate medical screenings, underfunding, and overcrowding[.]” Thus, it reversed the district court’s grant of the County’s motion to dismiss as to the failure to train claim but affirmed as to plaintiff’s other municipal liability claims. As to the first element of the failure to train claim, the court found the complaint plausibly established “that the County’s training program did not adequately teach jail staff how to recognize and respond to medical emergencies relating to drug overdoses.” The court noted that jail staff did not “provide or call for any medical care upon Lewis’s arrival, despite surveillance footage depicting him ‘unstable on his feet and hunched over,’ Lewis’s previous admission that he had taken drugs, and the officers’ discovery of drug paraphernalia and a powdery substance in his vehicle.” Throughout the approximately 17 hours he was at the detention facility, at least 10 individuals interacted with him. “Despite having policies in place, not even one individual properly medically screened Lewis, regularly monitored him, or otherwise sought or provided medical care—even as he defecated uncontrollably on himself, laid in his own feces, and banged his head into his cell door.” And after staff eventually discovered he was not breathing, they “administered chest compressions, but no one called 911 for another 40 minutes.” The court also held that plaintiff sufficiently pled the deliberate indifference element. It concluded this case presented “one of the ‘narrow’ circumstances from which we may infer deliberate indifference based on a single incident.” It found the two components of the “obviousness” required for the single-violation path were supported by the complaint’s allegations. Finally, the court held that plaintiff satisfied the third element, causation. “Had even one person recognized that Lewis was experiencing an overdose, they may have provided or otherwise sought out medical care that could have saved his life.”