Michael Brinkley v. Hamilton County, Tenn.

• Court: Court of Appeals for the Sixth Circuit
• Decided: March 21, 2025
• Docket: 24-5766
• Status: Unpublished

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0157n.06

No. 24-5766

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Mar 21, 2025 KELLY L. STEPHENS, Clerk ) MICHAEL RAY BRINKLEY, ) Plaintiff-Appellant, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE EASTERN ) DISTRICT OF TENNESSEE HAMILTON COUNTY, TENNESSEE, et al., ) Defendants-Appellees. ) OPINION ) )

Before: CLAY, BUSH, and BLOOMEKATZ, Circuit Judges.

BLOOMEKATZ, Circuit Judge. Michael Brinkley, a pretrial detainee at a Tennessee

county jail, was attacked and stabbed multiple times by fellow inmates. He sued the county and its

sheriff, claiming his injuries resulted from their deliberate indifference to inmate safety. The

district court granted summary judgment to the defendants, holding that Brinkley failed to create

a genuine dispute on whether he suffered a constitutional violation. We affirm.

BACKGROUND1

Michael Brinkley was detained at the Hamilton County Jail in Chattanooga, Tennessee

while he awaited trial on federal drug charges. In September 2021, he informed a corrections

officer that he felt unsafe in his housing unit because of his gang affiliation, stating that members

of his gang were “no longer welcome” in that unit. Pl.’s Statement of Facts, R. 39-2, PageID 592.

1 We recite the facts in the light most favorable to Brinkley, the non-moving party. Jackson v. City of Cleveland, 925 F.3d 793, 806 (6th Cir. 2019). No. 24-5766, Brinkley v. Hamilton County

Brinkley asked to transfer to a different unit that he believed was safer for inmates with his

affiliation. The jail granted his request.

After transferring, Brinkley learned that there were also inmates in the new unit who

wished him harm. At some point after his transfer, the jail placed one floor of his new unit on

lockdown. During the lockdown, Brinkley noticed his cell door remained unlocked. He “pounded

on the door of the dayroom and yelled for three nearby officers” to secure his cell, but the officers

did not respond. Brinkley Decl., R. 42, PageID 608–09. Five inmates then attacked Brinkley,

stabbing him “nine times, including once in the face.” Id. at PageID 609.

Brinkley sued Hamilton County and Sheriff Jim Hammond—individually and in his

official capacity—under 42 U.S.C. § 1983.2 In his operative complaint, Brinkley alleges that the

defendants violated his Eighth Amendment rights by failing to protect him from inmate-on-inmate

violence.3 He brings a separate Monell claim against the County, alleging that it failed to train,

supervise, and discipline its officers regarding inmate safety. He also asserts several claims under

Tennessee law.

The district court granted summary judgment to the County and the Sheriff on Brinkley’s

federal claims and declined to exercise supplemental jurisdiction over Brinkley’s remaining state

law claims. Brinkley timely appealed.

2 Initially, Brinkley also listed fifteen unnamed correctional officers as defendants, but he later removed them when he amended his complaint. 3 Because Brinkley was a pretrial detainee at the time of the attack, his claims arise under the Fourteenth Amendment, not the Eighth Amendment. See Lawler ex rel. Lawler v. Hardeman County, 93 F.4th 919, 926 (6th Cir. 2024).

-2- No. 24-5766, Brinkley v. Hamilton County

ANALYSIS

We review the district court’s grant of summary judgment de novo. Jackson v. City of

Cleveland, 925 F.3d 793, 806 (6th Cir. 2019). We view the evidence in the light most favorable to

Brinkley and affirm if he has failed to present evidence from which a reasonable jury could find

in his favor. See id.

The Sheriff. The only individual defendant remaining in this case is Sheriff Hammond. To

the extent Brinkley sues the Sheriff in his personal capacity, his failure-to-protect claim requires

evidence of the Sheriff’s personal involvement in the alleged misconduct. See Grinter v. Knight,

532 F.3d 567, 575 (6th Cir. 2008); Miller v. Calhoun County, 408 F.3d 803, 817 n.3 (6th Cir.

2005). Brinkley offers no such evidence, so his personal-capacity claim fails. As for his official-

capacity claim under Monell, that functions as a claim against the County. See Essex v. County of

Livingston, 518 F. App’x 351, 354 (6th Cir. 2013). The key question, then, is whether Brinkley

has raised a genuine dispute regarding the County’s liability for his injuries.

The County. Under § 1983, local governments are not liable simply because they employ

someone who commits a constitutional violation—that is, they are not liable under a respondeat

superior theory. Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 691 (1978). Rather, municipal

entities are responsible for injuries caused by their “policy or custom.” Id. at 694. So, to prevail on

his claim against the County, Brinkley must create a genuine dispute that he suffered a

constitutional injury because of a County policy or practice. On that front, Brinkley says that his

stabbing resulted from a County policy of inadequate training, supervision, and discipline

regarding inmate safety. To succeed on that theory, Brinkley must present evidence that (1) County

employees received inadequate training or supervision regarding inmate safety; (2) the inadequacy

-3- No. 24-5766, Brinkley v. Hamilton County

resulted from the County’s deliberate indifference; and (3) the inadequacy was closely related to

or actually caused his injuries. See Franklin v. Franklin County, 115 F.4th 461, 474 (6th Cir. 2024).

Brinkley has failed to develop any evidence to support his claim. The only facts he cites

regarding the County’s training, supervision, and discipline come from allegations in his

unverified complaint. But, as the district court correctly noted, an unverified complaint does not

provide competent evidence at summary judgment. See King v. Harwood, 852 F.3d 568, 577–78

(6th Cir. 2017); Worthy v. Mich. Bell Tel. Co., 472 F. App’x 342, 343 (6th Cir. 2012). Apart from

his complaint, Brinkley relies solely on conclusory assertions, which cannot sustain his claim at

this stage. See Arendale v. City of Memphis, 519 F.3d 587, 601, 605 (6th Cir. 2008). Because he

has failed to introduce evidence showing that his injuries resulted from a County policy or custom,

his claim against the County fails.

CONCLUSION

We affirm the district court’s grant of summary judgment to the defendants.

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