Kuhl v. Fields

CourtDistrict Court, E.D. Kentucky
DecidedFebruary 11, 2025
Docket2:21-cv-00057
StatusUnknown

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

Bluebook
Kuhl v. Fields, (E.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY NORTHERN DIVISION AT COVINGTON

CIVIL ACTION NO. 21-57-DLB-EBA

KATHLEEN KUHL, et al. PLAINTIFFS

v. MEMORANDUM OPINION AND ORDER

KEVIN IGO DEFENDANT

*** *** *** *** *** *** I. INTRODUCTION This matter is before the Court upon two Motions filed by Defendant Officer Kevin Igo: (1) the Motion to Strike Opinions of Plaintiff’s Expert, Angela Goehring (“Motion to Strike”) (Doc. # 75); and (2) the Motion for Summary Judgment (Doc. # 77). The Motions have been fully briefed and are therefore ripe for review. For the following reasons, the Motion for Summary Judgment is granted, and the Motion to Strike is denied as moot. II. FACTUAL AND PROCEDURAL BACKGROUND The facts of this case are largely undisputed and are well documented by various video footage and incident reports. At approximately 11:00 a.m. on April 29, 2020, Covington police officers were dispatched to Charles Kuhl’s residence. (Doc. # 77-1 at 3). Upon arrival, officers called an ambulance for Mr. Kuhl, who was transported by EMTs to the emergency room at the St. Elizabeth Medical Center (“SEMC”) in Covington, Kentucky for a suspected overdose. (Id. at 2). Following treatment at SEMC, Mr. Kuhl discharged himself against medical advice. (Doc. # 70-2).1 Mr. Kuhl is then seen on SEMC video footage walking outside with his belongings, walking back in, falling backwards, hitting his head, and then displaying seizure like symptoms. (Doc. # 88-1, 1:22). Mr. Kuhl was subsequently treated for the seizure, and the SEMC report noted the impression of a closed head injury and ingestion of substance. (Doc. # 77-3 at 1). Mr.

Kuhl was then placed on a 72–hour hold because he was “unsteady with attempts to ambulate” and was “not safe to be discharged.” (Doc. # 77-2). However, Mr. Kuhl soon became aggressive and uncooperative. (Id.). Staff at SEMC ultimately contacted Covington Police Department due to Mr. Kuhl’s aggressive and uncooperative behavior. (Doc. # 77-4 at 1). The Kenton County Call for Service Report details that SEMC staff called 911 at 5:04 p.m., with the call narrative stating that Mr. Kuhl was “fighting with the staff” and was “not sick enough to stay there.” (Id.). The emergency department report, made at 5:05 p.m., noted this phone call and that Mr. Kuhl was medically cleared for jail. (Doc. # 77-2).

Defendant arrived at SEMC at 5:06 p.m. (Doc. # 77-4 at 2). As seen on Defendant’s body camera video footage, upon arrival, SEMC staff tell Defendant that Mr. Kuhl was “too unsteady to send him out on his own, and too uncooperative to stay here.” (Doc. # 77-5 at 1:38-1:43). SEMC staff then briefly explained to Defendant that Mr. Kuhl was there originally for an overdose, and that after he was released, he had fallen and hit his head and seized. (Id. at 1:50-1:59). The SEMC staff member then verbally told Defendant that Mr. Kuhl was medically cleared and handed Defendant a cleared for jail

1 These facts are uncontested and were summarized from SEMCs certified medical records. (Doc. # 70-2). The medical records were produced by the Kenton County Detention Center Defendants in their Motion for Summary Judgment (Doc. # 70) and cited by Plaintiff in her Response brief in the current matter (Doc. # 94). note. (Id. at 1:56-3:18). The note states that Mr. Kuhl was “seen and treated” by SEMC and was “medically cleared to go to jail.” (Doc. # 77-6). As Mr. Kuhl and Defendant are attempting to leave the emergency department, Mr. Kuhl began to look through the trashcan for his belongings, which prompted another SEMC staff member to direct Mr. Kuhl to where his belongings were actually placed. (Doc. # 77-5 at 2:30-2:36). Mr. Kuhl

then told Defendant he was highly disoriented, and when asked why he was disoriented, responded with unintelligible mumbling, with a mention of Seroquel. (Id. at 2:40-2:49). Mr. Kuhl and Defendant then walked to the SEMC sallyport, where Mr. Kuhl is visibly unsteady and needed direction to leave the building. (Id. at 3:46-4:10). As Mr. Kuhl was standing in the sallyport, he continued to be visibly unsteady, tripping over himself, dropping his belongings, and needing assistance to stand up. (Id. at 4:13-5:30). After observing Kuhl’s actions, Officer Igo arrested Mr. Kuhl for public intoxication (controlled substance) and criminal trespassing 3rd degree. (Doc. # 77-7); (see also Doc. # 77-5 at 5:15-5:20). After pulling his car closer to the sallyport, Defendant helped Mr.

Kuhl into the police vehicle. (Id. at 6:00-8:00). As Defendant searched through Mr. Kuhl’s backpack he discovered six used syringes. (Id. at 8:19-13:00). While Mr. Kuhl was sitting in Defendant’s vehicle, he displayed signs of hallucinations, paired with incoherent mumbling. (Id. at 13:00-38:50). Mr. Kuhl and Defendant arrived at the sallyport of the Kenton County Detention Center (“KCDC”) around 6:00 p.m. (Doc. # 77-4 at 2). Upon arriving at the KCDC, Mr. Kuhl continued to display difficulty speaking clearly and was visibly unsteady. (Doc. # 77- 5 at 39:40-41:25). Mr. Kuhl additionally needed help getting out of Defendant’s vehicle and was brought a chair so he could sit outside the KCDC. (Id.). At that time Defendant left Mr. Kuhl in the care of the KCDC. (Id. at 46:40-47:00). Mr. Kuhl was found unresponsive the next day on April 30, 2020. (Doc. # 77-9 at 2). Based on the above, Kathleen Kuhl (“Plaintiff”), individually and as administratrix of the estate of Charles Kuhl, filed a Complaint on April 29, 2021. (Doc. # 1). Later, Plaintiff was granted leave to file an amended complaint, which was filed on October 26,

2021. (Doc. # 21). In the First Amended Complaint, Plaintiff brought numerous claims against Defendant. After all Defendants’ Motion for Partial Judgment on the Pleadings was filed and briefed,2 this Court dismissed with prejudice Counts VII and VIII. (Doc. # 41). Defendant then filed the instant summary judgment Motion (Doc. # 77) on all remaining claims, as well as the Motion to Strike (Doc. # 75). In her Response to Defendant’s summary judgment Motion, Plaintiff voluntarily waived her excessive force (Count IV), failure to protect (Count V), and battery claims (Count X), leaving two remaining claims. (Doc. # 94 at 21). III. ANALYSIS

A. Standard of Review Defendant has moved for summary judgment on Plaintiff’s remaining claims of deliberate indifference (Count I) and wrongful death (Count VI). (Doc. # 77). Summary judgment is appropriate “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). In deciding a motion for summary judgment, the court must view the evidence and draw all reasonable inferences in favor of the nonmoving party. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986).

2 The Partial Motion for Judgment on the Pleadings was filed by all Defendants, including Officer Igo, at that time. Those Defendants are not parties to this Motion. “The moving party bears the burden of showing the absence of any genuine issues of material fact.” Sigler v. Am. Honda Motor Co., 532 F.3d 469, 483 (6th Cir. 2008). The movant may do so by “citing to particular parts or materials in the record, including depositions, documents, electronically stored information, affidavits or declarations, stipulations (including those made for purposes of the motion only), admissions,

interrogatory answers, or other materials[.]” Fed. R. Civ. P. 56

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