Case Citator › Phillips v. Roane County, Tenn.

Phillips v. Roane County, Tenn.

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
Sixth Circuit
Citation
534 F.3d 531
Decided
Confirmed treatments
1
Flagged citations read
40 of 40
Citing cases (total)
40
Treatment dates
2021
Abrogated
A reviewed court treats this case as abrogated by later authority. Phillips v. Roane County, Tenn. has been abrogated in part on the proof required for a pretrial detainee’s medical care claim; all 40 flagged citations have been read, and the confirmed treatment is listed below. Brawner v. Scott County replaced the requirement that an official actually recognize a serious risk with a recklessness standard that also reaches an obvious risk the official should have recognized.
More on how this was screened

Later courts continue to cite Phillips for the seriousness of an obvious medical need, qualified immunity, and supervisory liability.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

40 later cases cite Phillips v. Roane County, Tenn.; 40 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Phillips v. Roane County, Tenn.?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Abrogated

  • The Sixth Circuit displaced Phillips's requirement that a pretrial detainee prove an official actually perceived a serious medical risk, allowing liability when the risk was so obvious the official should have known.

    Brawner v. Scott County · Sixth Circuit · filed

    Accordingly, we agree with the Second, Seventh, and Ninth Circuits that Kingsley requires modification of the subjective prong of the deliberate-indifference test for pretrial detainees.
    Read the full opinion on CourtListener →

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