Dana Hale v. County of Clinton, Michigan — 6th Cir. (Oct 22, 2026)
The Sixth Circuit considers a man’s death in a Michigan county jail. Christopher Fisher arrived at the Clinton County jail appearing normal and denying drug use. Later, video showed him becoming unsteady and struggling to stay awake. He was found unresponsive the next morning; an autopsy attributed his death to methamphetamine and fentanyl overdose. His estate says jail officers should have recognized a medical emergency and obtained help. The officers dispute what they saw and knew. The district court allowed the claim against two officers to continue, finding factual disputes rather than deciding they were liable. Those officers appealed the denial of qualified immunity. That protection bars a civil damages claim unless the officers violated a right that was clearly established at the time. Here, that means asking both whether their response violated the Constitution and whether existing law clearly warned them that this conduct was unlawful. A recent Sixth Circuit decision, Poynter, makes actual knowledge central. Deliberate indifference requires knowing of a substantial risk of serious harm and disregarding it, not simply failing to exercise reasonable care. The judges will consider whether to return this case to the district court to apply that standard, or resolve the immunity question now. On this appeal, disputed facts must be viewed in the estate’s favor; that is not a finding that its account is true. Kevin Campbell will argue for the officers that the behavior shown was not the unmistakable emergency seen in earlier cases, and that those decisions did not clearly establish liability here. Christopher Desmond, for Fisher’s estate, will argue that the officers’ training, their proximity to the cell and the video permit a jury to infer they recognized the danger. The disagreement is about what each officer knew, and what the law required them to do.
Dana Hale v. County of Clinton, Michigan (No. 26-1126) — U.S. Court of Appeals for the Sixth Circuit, argued October 22, 2026.
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