Luther Poynter v. Aaron Shirley

Summary

The Sixth Circuit held that the Supreme Court’s Farmer subjective‑knowledge standard, not the objective approach derived from Kingsley or Brawner, governs Fourteenth Amendment deliberate‑indifference failure‑to‑protect claims. Accordingly, it vacated the district court’s summary‑judgment order that applied the Westmoreland framework and remanded for reconsideration under Farmer. The court also rejected the parties’ reliance on the party‑presentation principle to avoid deciding the proper standard.