Burt v. Hamilton County

CourtDistrict Court, E.D. Tennessee
DecidedAugust 27, 2025
Docket1:23-cv-00192
StatusUnknown

This text of Burt v. Hamilton County (Burt v. Hamilton County) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Burt v. Hamilton County, (E.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT CHATTANOOGA

AMY BURT, in her capacity as ) administrator and personal representative ) for the estate of TIMOTHY BURT, ) deceased, ) ) Plaintiff, ) Case No. 1:23-cv-192 ) v. ) Judge Atchley ) HAMILTON COUNTY, TENNESSEE, ) Magistrate Judge Steger and HAMILTON COUNTY SHERIFF JIM ) HAMMOND, ) ) Defendants. )

MEMORANDUM OPINION

Plaintiff, by and through counsel, filed this civil rights action under 42 U.S.C. § 1983 in her capacity as the Administrator and Personal Representative of the Estate of Timothy Burt, who died on August 27, 2022, following his incarceration at the Hamilton County Jail and Detention Center (hereinafter “Jail”) [Doc. 1].1 Specifically, Plaintiff claims that (1) the policies and customs of the Hamilton County Sheriff’s Office (“HCSO”) caused Mr. Burt to be deprived of his constitutional rights [Count I]; (2) Defendants’ failure to train violated Mr. Burt’s constitutional rights [Count 2]; (3) Defendants’ failure to supervise violated Mr. Burt’s constitutional rights [Count 3]; and (4) Defendants were deliberately indifferent to Mr. Burt’s medical needs [Count 4] [Id.]. Before the Court are Defendants’ motion for summary judgment [Doc. 30] and supporting exhibits [Docs. 31-38]; Plaintiff’s response in opposition and supporting exhibits [Docs. 45–49, 51-56, 58, 70]; and Defendants’ reply and supplement [Doc. 68–69]. Upon consideration of the

1 Plaintiff states in her complaint that she is Mr. Burt’s sister [Doc. 1 ¶ 4]. Plaintiff’s medical records indicate that Plaintiff is Mr. Burt’s daughter [See, e.g., Doc. 51-1 at 86]. Parties’ pleadings, the evidence presented, and the applicable law, the Court finds Defendants’ motion [Doc. 30] should be GRANTED, and this action DISMISSED. II. SUMMARY JUDGMENT STANDARD Summary judgment is proper when the pleadings and evidence, viewed in a light most favorable to the nonmoving party, illustrate that no genuine issue of material fact exists, and the

movant is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a), (c); Celotex Corp. v. Catrett, 477 U.S. 317, 322–23 (1986). A fact is deemed “material” if resolving that fact in favor of one party “might affect the outcome of the suit under governing law.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). To establish an entitlement to summary judgment, the moving party must demonstrate that the nonmoving party cannot establish an essential element of their case for which they bear the ultimate burden of proof at trial. Celotex, 477 U.S. at 322; Moore v. Philip Morris Cos., Inc., 8 F.3d 335, 339 (6th Cir. 1993). Once the motion is properly supported with competent evidence, the nonmovant must show that summary judgment is inappropriate by setting forth specific facts showing there is a genuine

issue for trial. Celotex, 477 U.S. at 323; Anderson, 477 U.S. at 249. The plaintiff cannot meet this burden with “some metaphysical doubt as to the material facts,” Matsushita Elec. Indus. Co., Ltd. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986), “conclusory allegations,” Lujan v. Nat’l Wildlife Fed’n., 497 U.S. 871, 888 (1990), or by a mere “scintilla” of evidence, Anderson, 477 U.S. at 252. If the “evidence is such that a reasonable jury could return a verdict for the nonmoving party,” then there is a genuine dispute as to a material fact. Anderson, 477 U.S. at 248. If no proof is presented, however, the Court does not presume that the nonmovant “could or would prove the necessary facts.” Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (5th Cir. 1994) (citing Lujan, 497 U.S. at 889). 2 II. BACKGROUND A. Circumstances Preceding and Involving Mr. Burt’s Death On May 28, 2022, sixty-five-year-old Timothy Burt was admitted to the Dekalb Regional Medical Center in Fort Payne, Alabama, complaining of chest pains and shortness of breath [Doc. 51-1 at 60]. His weight was recorded at 119 pounds a few days after his admittance [Id. at 57].

Mr. Burt remained hospitalized for approximately a month and was treated for, among other conditions, cardiac and pulmonary issues, sepsis, alcohol withdrawal, and delirium [Id. at 58, 72]. Cardiology planned to perform a heart catheterization during this hospitalization, but Mr. Burt “was too altered to do it safely” [Id. at 72]. Plaintiff’s expert, Dr. Haggerty, opines that these events “painted a clear picture of a high probability of death in the very near and short term” [Doc. 45-1 ¶ 21]. The hospital and Mr. Burt’s family worked together to attempt to get him placed in a facility upon his discharge from the hospital, but those efforts were unsuccessful [See Doc. 51-1 at 85–87]. And days prior to his release, the hospitalist recorded “that [Mr. Burt] is not competent

to care for himself or conduct any business transactions” [Id. at 55]. However, with medical intervention and the absence of alcohol during his hospital stay, Mr. Burt’s mental status slowly improved to the point he was deemed “safe for discharge” [Id. at 72]. On June 28, 2022, Mr. Burt was discharged from Dekalb, and a car provided by the hospital dropped him off at the home of his sister and brother-in-law [Doc. 51-1 at 93, 97; see also Doc. 45-5 ¶ 5]. The following day, family members took Mr. Burt to Erlanger Medical Center (“Erlanger”) in Chattanooga, Tennessee, and requested placement for him [Doc. 51-1 at 96, 100]. According to the Erlanger record, Mr. Burt’s “sister and brother-in-law have been taking care of him since yesterday; however, they are unable to further take care of him as he frequently roams 3 and gets into things that he should not get into. Brother-in-law is concerned as it appears that he has no inhibition and they are unable to keep him out of the house as they are concerned for their safety as well as his safety.” [Id. at 96]. A physician’s note documented Mr. Burt’s history of alcohol use disorder and indicated that Mr. Burt was “[o]bviously confused” at the time of his admission, as he was “sitting on the ground and attempting to pull his pants down” [Id. at 96–97].

Mr. Burt’s weight was recorded at 100 pounds at the time [Id. at 96]. After Mr. Burt’s medical records were received and reviewed, a physician noted “concern[] that patient has Koraskoff syndrome2 and likely needs SNF3 placement” [Id. at 97]. On June 30, 2022, Mr. Burt was “hand[ed][]off” to Dr. Gray and admitted to the adult hospitalist at Erlanger [Id. at 97, 99]. At approximately 8:30 a.m. that morning, while still in the hospital’s care, Mr. Burt walked outside, climbed in an ambulance, and drove away [Doc. 51-1 p. 99; Doc. 38-1]. Police were notified and followed Mr. Burt [Doc. 51-1 p. 99]. Eventually, the ambulance driven by Mr. Burt struck a Chattanooga Police Department patrol vehicle at a low rate of speed [Id. at 99]. The authorities pulled Mr. Burt out of the ambulance and returned him to

Erlanger, where he was treated for his pre-existing conditions, some abrasions to the right side of his face that he presumably got “fighting with police” as he was removed from the ambulance, and a urinary tract infection [Id.]. The same day, Mr. Burt’s sister and brother-in-law were granted temporary letters of guardianship over Mr.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Little v. Liquid Air Corp.
37 F.3d 1069 (Fifth Circuit, 1994)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
City of Oklahoma v. Tuttle
471 U.S. 808 (Supreme Court, 1985)
Kentucky v. Graham
473 U.S. 159 (Supreme Court, 1985)
Pembaur v. City of Cincinnati
475 U.S. 469 (Supreme Court, 1986)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Lujan v. National Wildlife Federation
497 U.S. 871 (Supreme Court, 1990)
Feliciano v. City of Cleveland
988 F.2d 649 (Sixth Circuit, 1993)
Cardinal v. Metrish
564 F.3d 794 (Sixth Circuit, 2009)
Madewell v. Garmon
484 F. Supp. 823 (E.D. Tennessee, 1980)
Lucas Burgess v. Gene Fischer
735 F.3d 462 (Sixth Circuit, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Burt v. Hamilton County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/burt-v-hamilton-county-tned-2025.