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Abstract: 

Jeff Horvath was booked into the Wayne County, Michigan jail on an outstanding warrant for a non-violent misdemeanor. Eight days later he was dead after a vicious, murderous assault by Brandon Gillespie who was housed with him the day before. In a ruling that hinges on the difficult question of deliberate indifference, the Sixth Circuit has permitted plaintiff’s case in Richko v. Wayne Co. Mich., 819 F.3d 907 (6th Cir. 2016) to proceed to trial. This article examines the facts of the case, a significant one because during intake screening, the jail social worker uncovered information about inmate Gillespie that should have led to his being celled alone.

Keywords: Richko v. Wayne Co. Mich; undue delay; duty to care

Affiliations:  1: Executive Editor.