Case Citator › Napier v. Madison County

Napier v. Madison County

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

Abrogated
Court
Sixth Circuit
Citation
238 F.3d 739
Decided
Confirmed treatments
1
Flagged citations read
48 of 48
Citing cases (total)
48
Treatment dates
2021
Abrogated
A reviewed court treats this case as abrogated by later authority. Napier v. Madison County was abrogated on the subjective standard for a pretrial detainee's medical-care claim. The Sixth Circuit held in Brawner v. Scott County that a detainee can establish deliberate indifference through reckless disregard of an obvious risk, without proving the official actually recognized it.
More on how this was screened

Napier's separate requirement for medical evidence of harm from delayed treatment continues to be applied in convicted prisoners' claims. All 48 flagged citations have been read; the confirmed treatment is listed below. The later Sixth Circuit opinion in Lawler v. Hardeman County identifies Napier among the decisions that had applied the same subjective standard to detainees and convicted prisoners, and attributes the change to Brawner. The many district court references to “abrogation on other grounds” report that earlier change; they are not separate treatments. See source.

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.

48 later cases cite Napier v. Madison County; 48 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 Napier v. Madison County?

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 changed the deliberate-indifference test for pretrial detainees, displacing Napier's use of the convicted-prisoner subjective standard for those claims.

    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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