Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT JESSIE CANTRELL, Personal Representative of the Estate of Cory Cantrell v. SCIOTO COUNTY, OH, BOARD OF COMMIS- SIONERS OFFICER CHRISTOPHER BOGGS ) ) ) ) ) ) ) ) ) ) ) ) ) )

Court: United States Court of Appeals for the Sixth Circuit

Filed: 2026-07-13

The Sixth Circuit reversed the district court’s denial of qualified immunity and Ohio statutory immunity to Defendant-Appellant Officer Christopher Boggs, granting him summary judgment on the plaintiff’s Eighth Amendment and state-law tort claims. The court held that no clearly established law demonstrated that a reasonable officer should have perceived Cory Cantrell faced a serious risk of harm requiring immediate medical intervention at the time Officer Boggs interacted with him. The court applied the two-prong qualified immunity standard, determining that the plaintiff failed to identify binding precedent placing the constitutional question beyond debate. Under the objective prong, the court found no “sufficiently serious” medical need was obvious to laypersons based on the symptoms observed by Officer Boggs, which included an inmate who was “acting up,” had a “goose egg” on his head, and verbally stated he was fine. Under the subjective prong, the court concluded there was no evidence that Officer Boggs actually perceived facts from which to infer a substantial risk of harm or disregarded such a risk. The court distinguished the plaintiff’s reliance on *Burwell v. City of Lansing*, noting that *Burwell* only found liability where an officer observed an inmate unconscious in a pool of vomit, whereas Officer Boggs observed symptoms consistent with ordinary intoxication and never witnessed the extreme symptoms that developed later. Because the standard for Ohio statutory immunity overlaps with the federal qualified immunity analysis, the court extended the same protection to the state-law claim. The practical consequence is that the case is remanded to the district court for the entry of summary judgment in favor of Officer Boggs, effectively ending his liability for the death of Cory Cantrell.

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