Miller v. Calhoun County.

• Position: PRETRIAL DETENTION - Brief Article

U.S. Appeals Court

MEDICAL CARE

TRAINING

Miller v. Calhoun County, 408 F.3d 803 (6th Cir. 2005). The sister of a detainee, who died of a brain tumor while in pretrial custody in a county facility, brought a wrongful death action under [section] 1983 alleging deliberate indifference to the detainee's medical needs and gross negligence. The district court granted summary judgment for the defendants and the sister appealed. The appeals court affirmed. The court held that county did not have a custom or policy of deliberate indifference so as to support a [section] 1983 claim, given that there was no evidence of a clear and consistent pattern of mistreatment of detainees, and that the shift commander followed the county's policy and contacted the on-call doctor. The court found that the shift commander did not act with deliberate indifference, noting that he questioned the...