Matthew Drew Miller v. County of Hamilton, Tennessee, et al.

Summary

The United States District Court for the Eastern District of Tennessee grants the defendants’ motions for summary judgment in Matthew Drew Miller’s action under 42 U.S.C. § 1983 and Tennessee law arising from his assault and medical treatment during incarceration at the Hamilton County Jail. The court holds that the plaintiff failed to establish individual liability for failure to protect, municipal or supervisory liability, or deliberate indifference to medical needs. The court declines supplemental jurisdiction over the state-law claims and dismisses the action.

Holdings

1. Plaintiff failed to present evidence that any individual defendant personally knew of or disregarded a substantial risk to Plaintiff before the assault, and the correctional officers and Sheriff Hammond were entitled to summary judgment on the Fourteenth Amendment failure-to-protect claims.
2. The individual Officer Defendants were alternatively entitled to qualified immunity because Plaintiff did not identify clearly established authority requiring officers to prevent an unforeseeable inmate assault or guarantee uninterrupted administration of particular medications.
3. QCHC and the Healthcare Defendants were entitled to summary judgment because Plaintiff did not present evidence that the single missed evening dose of HIV prophylaxis or the intermittent missed pain medications created a sufficiently serious risk of harm or resulted from deliberate indifference.
4. The County and Sheriff Hammond in his official capacity were entitled to summary judgment because Plaintiff failed to identify a policy or custom that was the moving force behind a constitutional violation and failed to establish inadequate training, inadequate supervision, or a custom of tolerance or acquiescence.
5. After granting summary judgment on all federal claims, the court declined to exercise supplemental jurisdiction over the remaining Tennessee-law claims and dismissed them without prejudice.

Questions Presented

1. Whether the correctional officers and Sheriff Hammond violated the Fourteenth Amendment by failing to protect Plaintiff from an assault by other inmates.
2. Whether QCHC and the healthcare defendants violated the Fourteenth Amendment through deliberate indifference to Plaintiff's medical needs, including missed HIV prophylaxis and pain medication.
3. Whether the County and Sheriff Hammond were liable under Monell for inadequate training, supervision, or a custom of tolerating constitutional violations.
4. Whether Plaintiff was entitled to additional discovery under Federal Rule of Civil Procedure 56(d) before resolution of summary judgment.
5. Whether the court should exercise supplemental jurisdiction over Plaintiff's remaining Tennessee-law claims after disposing of the federal claims.

Disposition

dismissed