Background
In 2018, John Griswold was arrested following a domestic disturbance and admitted to taking pills later identified as ulcer medication. After being medically cleared by doctors and discharged from a hospital, he was placed in a Livingston County jail cell. Several hours later, Griswold was found unresponsive and died of sudden cardiac death with toxic levels of Trazodone in his blood. His estate sued jail officials under the Civil Rights Act, alleging deliberate indifference to his medical needs. The district court denied qualified immunity to several officials, who appealed.
The court’s reasoning
The court reviewed the case de novo, focusing on whether the officials violated clearly established law. The court applied the objective prong of the deliberate indifference test, requiring the plaintiff to show that the medical need was so obvious that a layperson would recognize the necessity for medical attention. The court found that while Griswold vomited once and appeared lethargic, he did not exhibit signs of distress beyond that single incident. He moved his arms and legs, adjusted his position, and did not complain or seek help. The court distinguished this case from precedents where plaintiffs showed continuous, obvious signs of distress or unconsciousness. Because the need for medical care was not obvious, the officials were entitled to qualified immunity.
Griswold’s need for medical attention was not obvious, making this case distinguishable from Burwell.
Griswold v. Trinity Health Michigan, 26a0140p.06 (6th Cir. May 11, 2026)
What it means going forward
Jail officials are shielded from liability in similar cases where a detainee’s medical condition is not visibly obvious to a layperson, even if the detainee later dies.