Estate of Kelsey Wolfe, b/n/f Next of Kin Roger Wolfe and Melissa Sisk as Administrator of the Estate of Kelsey Wolfe v. Cocke County, Tennessee, Sheriff Armando Fontes, Jail Admin. Josh Hartsell, and CPT. Bob Schaff

Summary

The United States District Court for the Eastern District of Tennessee grants Defendants’ converted motion for summary judgment and dismisses the action arising from Kelsey Wolfe’s fentanyl-overdose death while incarcerated at the Cocke County Jail. The court rejects the individual-capacity, official-capacity, Monell, failure-to-protect, and inadequate-medical-care claims, finding no evidence of a constitutional violation or municipal liability. The court also grants summary judgment on any intended state-law claims because the complaint did not adequately plead them.

Holdings

1. The individual-capacity claims against Sheriff Fontes, Jail Administrator Hartsell, and Captain Schaff must be dismissed because the course of proceedings did not provide fair notice that they were being sued personally, and the record did not establish their personal involvement or active unconstitutional conduct.
2. The official-capacity claims against the individual defendants are dismissed as redundant of the claims against Cocke County.
3. Plaintiffs failed to establish a constitutional failure-to-protect violation or municipal liability based on Wolfe's access to fentanyl and resulting overdose.
4. Cocke County was entitled to summary judgment because Plaintiffs failed to identify a county policy or custom that was the moving force behind an underlying constitutional violation.
5. Plaintiffs failed to establish that Cocke County or its officers deliberately and recklessly disregarded Wolfe's serious medical needs.
6. Any intended Tennessee-law claims fail because the complaint did not state the facts supporting a state-law claim.

Questions Presented

1. Whether the individual defendants could be held liable in their individual capacities when the complaint did not clearly specify individual-capacity claims and the record showed no personal involvement in the alleged constitutional violations.
2. Whether the official-capacity claims against the sheriff, jail administrator, and captain were redundant because Cocke County was also named as a defendant.
3. Whether Plaintiffs presented sufficient evidence to establish a municipal liability claim under Monell based on failure to protect Wolfe from drugs or failure to provide adequate medical care.
4. Whether Plaintiffs stated or supported any Tennessee-law claims.
5. Whether summary judgment was appropriate on all claims.

Disposition

dismissed