Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT MICHAEL COLE, Administrator of the Estate of Deceased Branden Knight v. ASHTABULA COUNTY OHIO; ASHTABULA COUNTY SHERIFF’S DEPARTMENT; WILLIAM NIEMI, Sheriff; TAMMY ANTOUN Jail Administrator; DALE LOCHER; MERISSA MOFFETT; BRIAN WHITNEY; COLE FARINA; MARK JACKSON; TARYN SIEMERS; JOHN DOES 1–3 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-06-26 The Sixth Circuit affirmed the district court’s grant of summary judgment in favor of the defendants, dismissing the plaintiff’s § 1983 claims alleging deliberate indifference to medical needs and failure to protect against drug overdoses. The court held that the plaintiff failed to satisfy the objective prong of the deliberate-indifference standard under the Fourteenth Amendment’s Due Process Clause because the deceased detainee did not exhibit “obvious signs” of a serious medical need, such as vomiting, slurred speech, or loss of consciousness, which would have alerted a layperson to the necessity of medical attention. Regarding the failure-to-protect claim, the court ruled that the plaintiff failed to demonstrate “unfettered access to deadly drugs,” as there was no evidence of a widespread presence of contraband at the facility or a history of recent overdoses that officials ignored. Consequently, the court also affirmed the dismissal of the county’s Monell liability claim for failure to train and the state-law claims based on qualified immunity, noting that state-law immunity applies when federal constitutional rights were not violated. The practical consequence is that the judgment in favor of the defendants stands, and the estate’s lawsuit against the jail officials and Ashtabula County is terminated without relief. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.