John Griswold v. Trinity Health Michigan

── John Griswold v. Trinity Health Michigan ── Court: Court of Appeals for the Sixth Circuit Date: May 11, 2026 Category: General RECOMMENDED FOR PUBLICATION Pursuant to Sixth Circuit I.O.P. 32.1(b) File Name: 26a0140p.06 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT ┐ JOHN E. GRISWOLD, │ Plaintiff-Appellee, │ │ No. 25-1271 v. > │ │ TRINITY HEALTH MICHIGAN, dba St. Joseph Mercy │ Livingston, │ Defendant, │ │ │ TERRY DAVIS, Sergeant; TRAVIS LINDEN, Deputy, │ PATRICK TURCHI, Deputy; ALLISON SCHULTE, Deputy; │ ERIC VANVLEET, Deputy; KURT HEIOB, Deputy, │ VINCENT JOHN, Deputy, │ Defendants-Appellants. │ ┘ Appeal from the United States District Court for the Eastern District of Michigan at Detroit. No. 2:22-cv-10980—Robert Jerome White, District Judge. Argued: April 30, 2026 Decided and Filed: May 11, 2026 Before: GIBBONS, THAPAR, and LARSEN, Circuit Judges. _________________ COUNSEL ARGUED: Kali M. L. Henderson, SEWARD HENDERSON PLLC, Royal Oak, Michigan, for Appellants. Beth A. Wittmann, GRANZOTTO & WITTMANN, P.C., Berkley, Michigan, for Appellee. ON BRIEF: Kali M. L. Henderson, SEWARD HENDERSON PLLC, Royal Oak, Michigan, for Appellants. Beth A. Wittmann, Mark Granzotto, GRANZOTTO & WITTMANN, P.C., Berkley, Michigan, for Appellee.  No. 25-1271 Griswold v. Trinity Health Michigan, et al. Page 2 _________________ OPINION _________________ LARSEN, Circuit Judge. In 2018, law enforcement officers arrested John Griswold after a domestic disturbance. He admitted to taking several pills that were later identified as ulcer medication. After being medically cleared by doctors and discharged from the hospital, the officers placed Griswold in a jail cell. He died several hours later. Griswold’s estate sued several jail officials alleging deliberate indifference in violation of his constitutional rights. The district court denied qualified immunity to some of the officials, who now appeal. Because the officials are entitled to qualified immunity, we REVERSE. I. In this interlocutory appeal from the denial of qualified immunity, “[a] settled evidentiary hierarchy governs the factual landscape . . . .” Feagin v. Mansfield Police Dep’t, 155 F.4th 595, 601 (6th Cir. 2025). “We start with the available [video] footage, which largely captures the incident in question and leaves few facts in dispute.” Id. “For those moments where the footage does not aid our understanding, we fill in the blanks by considering disputed evidence in a light most favorable to [Griswold], completing the story with any uncontested factual assertions the [defendants] proffer.” Id. In October 2018, police from Brighton, Michigan, arrested John Griswold following a domestic disturbance. Officers at the scene found Griswold in the kitch