Case Citator › Darnell v. City of New York

Darnell v. City of New York

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

Declined by some courts
Court
Second Circuit
Citation
849 F.3d 17
Decided
Confirmed treatments
2
Flagged citations read
67 of 67
Citing cases (total)
67
Treatment dates
2020
Declined by some courts
At least one reviewed court has declined to follow this case. No reviewed court has overruled it. Two district courts outside the Second Circuit declined to follow Darnell v. City of New York's objective standard for pretrial detainee claims. The Fourth Circuit later adopted that standard in Short v. Hartman, reducing the present force of the North Carolina decision below.
More on how this was screened

All 67 flagged citations have been read; the 2 confirmed treatments are listed below.

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.

67 later cases cite Darnell v. City of New York; 67 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 Darnell v. City of New York?

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

Declined to follow

  • The Southern District of Georgia rejected Darnell's objective mental element for detainee deliberate indifference claims because it applied Eleventh Circuit precedent requiring subjective knowledge.

    Benavides v. Gartland · S.D. Ga. · filed

    see also Darnell v. Pineiro, 849 F.3d 17, 35 (finding that the subjective prong of a deliberate indifference claim is “defined objectively” under the Fourteenth Amendment), a proposition that—as discussed above—has been rejected by binding precedent in this circuit.
    Read the full opinion on CourtListener →

  • The Western District of North Carolina applied the subjective standard of its circuit instead of Darnell's objective standard; the Fourth Circuit later adopted the objective standard in Short v. Hartman.

    Michelson v. Miller · W.D.N.C. · filed

    Some circuits have held, in light of Kingsley, that an objective reasonableness standard should apply in custodial contexts beyond excessive force. See, e.g., Hardeman v. Curran, 933 F.3d 816 (7th Cir. 2019) (extending the objective standard to conditions of confinement cases); Darnell v. Pineiro, 849 F.3d 17, 35 (2d Cir. 2017) (same); Castro v. City of Los Angeles, 833 F.3d 1060, 1069-70 (9th Cir. 2016) (en banc) (extending the objective reasonableness standard to failure to protect claims). ... The Court will apply the deliberate indifference standard in this case, as the relevant Fourth Circuit case law has not been overruled and the Fourth Circuit has not expressed any intention to do so.
    Read the full opinion on CourtListener →

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