Summary
Pretrial detainee suffered a stroke while in custody; corrections officers failed to provide timely medical care. The Sixth Circuit held that the Tennessee Governmental Tort Liability Act's "civil rights exception" (Tenn. Code Ann. § 29-20-205(2)) bars negligence claims against a county when the injury arises out of civil rights allegations, even if the underlying § 1983 claim has been dismissed. The district court properly declined supplemental jurisdiction over the TGTLA claims after dismissing the federal claims, consistent with Tennessee's preference for state court adjudication of such claims. The court vacated the district court's contrary rationale on the civil rights exception's timing to prevent collateral estoppel issues and denied the parties' joint motion to certify the question to the Tennessee Supreme Court.
Topics
Practice areas
Questions Presented
- Whether the district court erred in declining to exercise supplemental jurisdiction over the TGTLA negligence claims after dismissing the federal civil rights claims.
- Whether the district court's rationale in its 2018 order regarding the civil rights exception was erroneous and required vacatur to prevent collateral estoppel.
- Whether the parties' motion to certify a question to the Tennessee Supreme Court should be granted.
Holdings
- The district court did not abuse its discretion because the Tennessee legislature's clear preference for state court adjudication of TGTLA claims, as recognized in Gregory v. Shelby County, constitutes an exceptional circumstance under 28 U.S.C. § 1367(c) justifying the declination of supplemental jurisdiction.
- The statement was erroneous under Tennessee law, as clarified by Cochran, which holds that the civil rights exception applies if the injury arises out of civil rights, regardless of whether a civil rights claim remains pending. This error required vacatur of the rationale to prevent collateral estoppel in state court.
Key quotations
“Nothing in the language of section 29-20-205(2) indicates that there must be an express finding that a civil rights violation occurred in order for the exception to apply.” (at 10)
“But the Court has no need to determine whether Mr. Devereux's negligence claim arises out of his § 1983 claim because it has already concluded that his § 1983 claim requires dismissal, leaving no civil-rights claim standing against Knox County.” (at 11)
Factual background
Brian Devereux suffered a major stroke while in custody at the Knox County Detention Facility for a misdemeanor DUI conviction. He was motionless and unresponsive in a holding cell for approximately six hours. Corrections officers entered and exited the cell but did not provide medical attention until it was too late to mitigate the stroke's effects, resulting in permanent neurologic injury.
Procedural history
The district court dismissed all federal claims against Knox County and the individual officers, then declined to exercise supplemental jurisdiction over the remaining TGTLA negligence claims, dismissing them without prejudice. Knox County appealed, arguing that the district court should have retained jurisdiction and determined that the civil rights exception barred the negligence claims. The parties also moved to certify a question to the Tennessee Supreme Court.