Lombardo v. St. Louis

Nicholas Gilbert was arrested in St. Louis in December 2015 on minor warrants. While in a holding cell, he attempted suicide and was restrained by officers in a prone position with handcuffs, leading to his death. His mother, Jody Lombardo, sued the City of St. Louis and officers for excessive force. The district court granted summary judgment for defendants, and the Eighth Circuit affirmed, requiring proof of subjective deliberate indifference. On June 28, 2021, the U.S. Supreme Court reversed per curiam, holding that excessive force claims by pretrial detainees must be evaluated under the objective unreasonableness standard from Kingsley v. Hendrickson, not subjective intent.

The U.S. Supreme Court reversed and remanded per curiam, holding that the objective unreasonableness standard applies; no final liability determination was made.

Whether the Eighth Circuit applied the correct legal standard for excessive force claims brought by pretrial detainees, or improperly required subjective deliberate indifference instead of objective unreasonableness.

The decision clarified lower court standards for excessive force claims by pretrial detainees, reinforcing objective evaluation of police conduct, making it easier for plaintiffs to survive summary judgment, and promoting accountability in custodial death cases.