David Lovell v. Cnty. of Kalamazoo

── David Lovell v. Cnty. of Kalamazoo ── Court: Court of Appeals for the Sixth Circuit Date: April 10, 2026 Category: General RECOMMENDED FOR PUBLICATION Pursuant to Sixth Circuit I.O.P. 32.1(b) File Name: 26a0112p.06 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT ┐ DAVID LOVELL, as Personal Representative of the │ Estate of Chase Lovell, │ Plaintiff-Appellee, │ │ v. > No. 24-1876 │ │ COUNTY OF KALAMAZOO, MICHIGAN, et al., │ Defendants, │ │ │ LINDSEY O’NEIL; INTEGRATED SERVICES OF │ KALAMAZOO, a political subdivision of the State of │ Michigan, │ Defendants-Appellants. │ ┘ Appeal from the United States District Court for the Western District of Michigan at Grand Rapids. No. 1:22-cv-00567—Jane M. Beckering, District Judge. Argued: January 29, 2026 Decided and Filed: April 10, 2026 Before: GIBBONS, LARSEN, and MURPHY, Circuit Judges. _________________ COUNSEL ARGUED: Richard V. Stokan, Jr., KERR, RUSSELL AND WEBER, PLC, Detroit, Michigan, for Appellants. Christopher T. Putrycus, MARKO LAW, PLLC, Detroit, Michigan, for Appellee. ON BRIEF: Kevin A. McQuillan, KERR, RUSSELL AND WEBER, PLC, Detroit, Michigan, for Appellants. Christopher T. Putrycus, Jonathan R. Marko, Tyler M. Joseph, MARKO LAW, PLLC, Detroit, Michigan, for Appellee.  No. 24-1876 Lovell v. Cnty. of Kalamazoo Page 2 _________________ OPINION _________________ MURPHY, Circuit Judge. Chase Lovell’s mental-health struggles repeatedly led him to try to take his life. He arrived at a Michigan jail after starting a fire at a psychiatric hospital during one such suicide attempt. Lindsey O’Neil oversaw this jail’s mental-health unit. She originally ordered that Lovell stay in a padded cell and wear a suicide-prevention gown. When she later evaluated Lovell, however, she could tell that the padded cell and gown were causing him mental distress. O’Neil thus came up with a compromise. To alleviate the mental strain, she would move him to a less isolated cell and give him a regular jumpsuit. To reduce the risk that he would commit suicide, she would require Lovell to have a suicide-prevention blanket instead of regular bedding. Unfortunately, jail staff still gave Lovell regular bedding as a result of some type of miscommunication. Lovell used a sheet to commit suicide. His estate sued O’Neil, among several other defendants. The district court granted summary judgment to all defendants but O’Neil. She has appealed. We agree with O’Neil that no case would have clearly established that her compromise placement decision showed deliberate indifference to the risk that Lovell would commit suicide. Qualified immunity thus shields O’Neil from this damages suit. We reverse. I Lovell grew up in Manton, Michigan, and graduated