Factual context relevant to the legal analysis

• Tyler Venema had diagnosed mental illnesses including schizophrenia, a well-documented history of self-harm and suicide attempts (including prior plastic-bag asphyxiation and hanging by sheet), and was under a 90-day involuntary treatment order during decompensation when he was transferred to WCC’s inpatient program.
• Within days, Venema was assessed at “moderate” and then “intermediate” suicide risk and placed on Mental Health Management Plans (MHMPs) that: required a suicide-prevention gown/blanket; prohibited personal property, bedding, and writing implements; mandated staff to remain in close proximity, search each shift for dangerous contraband, observe/report self-harm, and intervene immediately.
• Officers West and Keys returned Venema’s clothing in a plastic bag and failed to remove the bag from his cell despite rounds and knowledge that plastic bags were dangerous contraband for at-risk inmates. Venema was found unresponsive with the bag over his head, later dying from asphyxia.
• The complaint alleges that Warden DeAngelo:
  • Had responsibility for training, supervision, policy-making/approval, and ensuring staff adherence to policy;
  • Knew plastic bags were suicide tools and dangerous contraband;
  • Knew officers were providing plastic bags to at-risk inmates and refraining from removing them; and
  • Failed to train, supervise, and enforce policies to prevent this risk, thereby implicitly authorizing or knowingly acquiescing in the unconstitutional conduct.

Precedents Cited and Their Influence

• Ashcroft v. Iqbal, 556 U.S. 662 (2009) and Bell Atl. v. Twombly, 550 U.S. 544 (2007)
  • Set the plausibility pleading standard and require personal involvement for individual-capacity claims. The dissent leans heavily on Iqbal/Twombly to argue the complaint’s knowledge allegations are conclusory. The majority accepts the estate’s knowledge allegations as well-pleaded facts at this stage, particularly given the procedural posture and appellate concession of those allegations.
• Peatross v. City of Memphis, 818 F.3d 233 (6th Cir. 2016)
  • Articulates that a supervisor may be liable where she “at least implicitly authorized, approved, or knowingly acquiesced” in unconstitutional conduct and that personal involvement need not be physical presence. The majority uses Peatross to confirm that failure to train and supervise, coupled with knowledge of subordinates’ unconstitutional practices, can plausibly constitute knowing acquiescence. The dissent reads Peatross as anchored in concrete facts (e.g., public admonitions and admissions) that are missing here.
• Coley v. Lucas County, 799 F.3d 530 (6th Cir. 2015)
  • Affirms supervisory liability where a sheriff failed to train/supervise and allegedly engaged in a cover-up of subordinates’ unconstitutional conduct. The majority clarifies that Coley does not impose a “cover-up” requirement; rather, knowledge may be pleaded directly and need not always be inferred from cover-up facts.
• Winkler v. Madison County, 893 F.3d 877 (6th Cir. 2018); Taylor v. Michigan Dep’t of Corrections, 69 F.3d 76 (6th Cir. 1995); Gregory v. City of Louisville, 444 F.3d 725 (6th Cir. 2006)
  • These cases support the notion that supervisory liability can attach when a supervisor “abandons the specific duties” of her position amid “actual knowledge of a breakdown” in operations that implicate constitutional risks. The majority uses these to characterize Warden DeAngelo’s alleged policy abdication in a mental-health facility as knowing acquiescence.
• Shehee v. Luttrell, 199 F.3d 295 (6th Cir. 1999); Essex v. County of Livingston, 518 F. App’x 351 (6th Cir. 2013)
  • Reiterate that supervisory liability requires more than respondeat superior and more than a mere failure to act; there must be active unconstitutional behavior directly correlated to the injury. The majority says the complaint crosses that threshold by alleging knowledge and abdication in the face of known contraband.
• Campbell v. City of Springboro, 700 F.3d 779 (6th Cir. 2012)
  • Supports pleading causation by alleging failures (policy creation, supervision) that could reasonably be expected to cause the specific harm (here, suicide using a known tool). The majority applies Campbell to find the causal chain plausible.
• Downard v. Martin, 968 F.3d 594 (6th Cir. 2020); Linden v. Washtenaw County, 167 F. App’x 410 (6th Cir. 2006); Schultz v. Sillman, 148 F. App’x 396 (6th Cir. 2005)
  • Provide the clearly established rule that deliberate indifference to a detainee’s strong likelihood of suicide violates the Constitution. The majority invokes these to satisfy the “clearly established” prong through the subordinates’ violation.
• Hart v. Hillsdale County, 973 F.3d 627 (6th Cir. 2020) and Moderwell v. Cuyahoga County, 997 F.3d 653 (6th Cir. 2021)
  • Warn that qualified immunity is often better resolved at summary judgment than at 12(b)(6), particularly on the clearly established prong. The majority nevertheless affirms denial here because the pleadings adequately allege a constitutional violation and because the clearly established law is well-settled regarding suicide risk.
• Dissent’s authorities: Crawford v. Tilley, 15 F.4th 752 (6th Cir. 2021); Caraway v. CoreCivic of Tenn., LLC, 98 F.4th 679 (6th Cir. 2024); Troutman v. Louisville Metro Dep’t of Corr., 979 F.3d 472 (6th Cir. 2020); Garza v. Lansing Sch. Dist., 972 F.3d 853 (6th Cir. 2020); Helphenstine v. Lewis County, 60 F.4th 305 (6th Cir. 2023)
  • The dissent emphasizes that conclusory “knowledge” allegations do not receive a presumption of truth; that pure failure-to-train theories belong to Monell municipal liability; and that plaintiffs must plead non-conclusory facts showing both active involvement and proximate causation by the supervisor.

Legal Reasoning

1) Qualified immunity framework at the pleading stage

The court applies the two-step qualified-immunity analysis: (a) do the pleaded facts show a constitutional violation; and (b) was the right clearly established? Exercising de novo review and accepting well-pleaded facts as true, the court is cautious about resolving qualified immunity at Rule 12(b)(6) but proceeds given the concession of facts on appeal.

2) Supervisory liability: knowing acquiescence and policy abdication

• Personal involvement: The estate must allege DeAngelo’s own actions—not vicarious liability—violated the Constitution. The complaint does so by alleging that DeAngelo knew officers were providing and not removing plastic bags to/from at-risk inmates, knew plastic bags were suicide tools, and failed to train, supervise, or enforce policy to prevent those practices.
• Knowing acquiescence: Relying on Peatross and Coley, the court holds that a plaintiff need not allege a cover-up to plead knowledge; knowledge can be directly alleged and, when combined with failure to train/supervise and policy abdication within the warden’s responsibilities, plausibly constitutes “implicit authorization, approval, or knowing acquiescence.”
• Abandonment of duties in a mental-health facility: Drawing on Winkler, Taylor, and Gregory, the court characterizes the warden’s alleged failure to maintain and enforce suicide-prevention and contraband policies—despite knowledge of a breakdown—as an abdication supporting supervisory liability.

3) Causation: reasonable foreseeability of the precise harm

Under Campbell, the complaint plausibly alleges that DeAngelo’s acts/omissions could be expected to lead to “just the sort of injuries that occurred.” In a unit housing decompensating, high-risk inmates, and given the specific MHMP requirements (close proximity, shift-by-shift contraband searches, immediate intervention), the alleged failure to train, supervise, and enforce a ban on plastic bags reasonably connects to an inmate’s death by bag asphyxiation.

4) Clearly established law: subordinate’s violation suffices

The court reiterates Sixth Circuit law that, for supervisory-liability qualified immunity, it is sufficient that the right violated by the subordinate officers was clearly established. Here, extensive pre-2017 case law clearly established that ignoring the strong likelihood of suicide violates the Eighth Amendment. Because West and Keys’ alleged deliberate indifference would violate clearly established law, the supervisory-liability claim against DeAngelo survives at this stage.

Impact and Implications

• Pleading standards for supervisory liability: The opinion clarifies that plaintiffs need not allege cover-ups or extensive prior patterns to plead a supervisor’s knowledge and knowing acquiescence. Direct allegations of knowledge, coupled with role-based responsibility and policy abdication, can suffice at Rule 12(b)(6).
• Corrections, mental-health, and suicide prevention: Wardens and supervisory officials in correctional mental-health settings should expect increased scrutiny where complaints allege knowledge of dangerous contraband and non-enforcement of suicide-prevention protocols. Policies on contraband (e.g., plastic bags) and MHMP compliance must be trained, enforced, and audited.
• Qualified immunity at the pleading stage: The court underscores the general preference to resolve qualified immunity at summary judgment but affirms denial at 12(b)(6) when the complaint plausibly alleges personal involvement and causation and when the governing constitutional right is clearly established.
• Clearly established prong in supervisory claims: The decision reaffirms that the clearly established inquiry can be satisfied by the subordinate officers’ clearly established violation, avoiding a separate, supervisor-specific clearly established right.
• Tension flagged by the dissent: The dissent’s insistence on non-conclusory knowledge allegations and proximate cause may fuel future defense arguments—particularly relying on Crawford, Caraway, and similar cases—to challenge complaints that lack details about how the supervisor acquired knowledge or about prior incidents. Expect litigation over what counts as a “well-pleaded” knowledge allegation post-Venema.

The Dissent’s Countervailing View

• Pleading sufficiency: The dissent argues the complaint’s statements that DeAngelo “knew” officers provided bags and failed to remove them are conclusory, not factual, and thus not entitled to a presumption of truth under Iqbal/Twombly.
• Active involvement: In the dissent’s view, supervisory liability demands specific facts showing active involvement—encouraging or directly participating in the misconduct—or at least facts demonstrating actual knowledge of ongoing unconstitutional practices (e.g., patterns, admonitions, or cover-up acts as in Peatross and Coley). Those are absent here.
• Causation: The dissent contends proximate cause is missing because, without non-conclusory allegations of knowledge or prior incidents, the harm was not reasonably foreseeable to the warden.
• Monell vs. individual liability: The dissent emphasizes that bare failure-to-train theories are Monell claims against municipalities, not individual-capacity claims against supervisors, which require more.

Bottom line from the dissent: Without specific, non-conclusory facts establishing knowledge and active involvement, qualified immunity should be granted to Warden DeAngelo at the pleading stage.