Sixth Circuit Court of Appeals reverses District Court in Spears v. Ruth
Posted on April 03, 2010
On December 10, 2009, the Sixth Circuit Court of Appeals reversed the holding of the United States District Court for the Eastern District of Tennessee at Chattanooga, finding no constitutional violation occurred in the case of Spears v. Ruth, 589 F.3d 249 (6th Cir. 2009).
In Spears, the Plaintiffs alleged the defendant police officer was deliberately indifferent to the medical needs of the decedent plaintiff, who ultimately died due to cocaine intoxication. Both the individual defendant police officer, as well as the City of Cleveland, Tennessee, were sued by Plaintiffs under a deliberate indifference to medical needs theory pursuant to 42 U.S.C. 1983 and the Fourteenth Amendment to the United States Constitution. The defendants filed a motion for summary judgment on that issue which was ultimately denied by the United States District Court for the Eastern District of Tennessee at Chattanooga.
On appeal, the Sixth Circuit Court of Appeals held that no such constitutional violation occurred in that the defendant officer's actions did not constitute deliberate indifference. Further, the Sixth Circuit held that City policies were not causally related to any constitutional injuries. The Sixth Circuit therefore reversed the holding of the District Court, instructing the District Court to enter judgment on behalf of the individual defendant officer and the City of Cleveland, Tennessee.