Connie Overstreet v. Ontonagon County

── Connie Overstreet v. Ontonagon County ── Court: Court of Appeals for the Sixth Circuit Date: May 08, 2026 Category: General RECOMMENDED FOR PUBLICATION Pursuant to Sixth Circuit I.O.P. 32.1(b) File Name: 26a0138p.06 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT ┐ CONNIE OVERSTREET, Personal Representative of the │ Estate of Paul Richard Bliven, │ Plaintiff-Appellant, │ │ > No. 25-1873 v. │ │ ONTONAGON COUNTY, MICHIGAN, a corporate subunit │ of government; DALE RANTALA, Sheriff, JASON │ DEVERE CLINESMITH, GIRARD WALDROP, DOUG │ WILLIAMS ROBERTS, and JOHN JASON HASENBERG, in │ their individual and official capacities, │ Defendants-Appellees. │ ┘ Appeal from the United States District Court for the Western District of Michigan at Marquette. No. 2:23-cv-00098—Maarten Vermaat, Magistrate Judge. Argued: April 30, 2026 Decided and Filed: May 8, 2026 Before: SUTTON, Chief Judge; CLAY and MURPHY, Circuit Judges. _________________ COUNSEL ARGUED: Racine M. Miller, THE MICHIGAN LAW FIRM, PC, Birmingham, Michigan, for Appellant. G. Gus Morris, MCGRAW MORRIS MASUD, Troy, Michigan, for Appellees. ON BRIEF: Racine M. Miller, THE MICHIGAN LAW FIRM, PC, Birmingham, Michigan, for Appellant. G. Gus Morris, John T. Gemellaro, MCGRAW MORRIS MASUD, Troy, Michigan, for Appellees.  No. 25-1873 Overstreet v. Ontonagon County, et al. Page 2 _________________ OPINION _________________ MURPHY, Circuit Judge. Paul Bliven committed suicide while a pretrial detainee in the Ontonagon County Jail. A representative of his estate sued the County and several of its corrections officers. She argued that the officers acted with deliberate indifference to the risk that Bliven would kill himself and that the County’s policies facilitated his suicide. But Bliven told the officers that he did not have any suicidal feelings and that he had never tried to commit suicide before. Qualified immunity thus protects the officers because a reasonable jury could not conclude that they knew of a strong likelihood that Bliven would take his life. And the County did not enact any jail policies with the deliberate indifference required to hold it liable for its employees’ actions. We thus affirm the district court’s grant of summary judgment to all defendants. I Bliven lived in Ontonagon County in Michigan’s Upper Peninsula. His mental-health struggles sometimes led him to mistakenly believe that criminals were “breaking into his home.” Rep., R.59-2, PageID 450. One such incident occurred on January 8, 2021. On that day, a worried Bliven called 911 and told the dispatcher that he had fled to his basement armed with a shotgun in fear of intruders. Deputies with the Ontonagon County Sheriff’s Department responded to the call. They found no evidence of intruders. Yet Bliven confessed that he had shot his firearm out the window. His neighbors confirmed that they heard at least two shots. They also expla