## Facts

- Juana Villegas, nine months pregnant, was arrested after a traffic stop for lacking a valid driver’s license and was booked into the Davidson County Sheriff’s Office jail.
- An immigration detainer was lodged through ICE’s 287(g) program, and Villegas was automatically classified as a medium-security inmate.
- Two days later, she went into labor and was transported to a hospital on a stretcher with her wrists handcuffed in front and her legs restrained together.
- At the hospital, her handcuffs were removed, but one leg remained shackled to the bed or stretcher during portions of the pre- and post-delivery period; restraints were removed for delivery and later reapplied to her ankle postpartum.
- The evidence conflicted on whether jail officers knew, or reasonably should have known, of medical directions not to restrain her during labor; testimony differed about what officers heard from medical staff and whether a “no-restraint order” was communicated.
- After returning to jail, Villegas alleged she was denied access to a breast pump, causing pain, risk of infection, and interference with breastfeeding.
- Villegas sued the Metropolitan Government under 42 U.S.C. § 1983, alleging unconstitutional treatment of a pretrial detainee based on shackling during childbirth and denial of a breast pump.

## Issues

1. Whether summary judgment for Villegas on the shackling claim was proper where disputes existed about flight/security risk, officer knowledge of medical restrictions, and medical harm, under the deliberate-indifference standard.
2. Whether summary judgment for Villegas on the breast-pump claim was proper given disputes about the seriousness of the medical need and the reasonableness of the jail’s response.
3. Whether the record established municipal liability as a matter of law under Monell (policy/custom as the moving force), as to either claim.

## Decision

- The Sixth Circuit reversed the district court’s grant of summary judgment for Villegas on both claims and remanded for further proceedings.
- The court held that material factual disputes precluded resolving deliberate indifference and municipal liability as a matter of law on summary judgment.
- The reversal vacated the district court’s liability determinations and required further factfinding before constitutional and Monell liability could be imposed.

## Legal Principles

- A pretrial detainee’s medical-care and conditions-of-confinement claims are assessed under the deliberate-indifference framework; where key facts are disputed, liability generally cannot be decided on summary judgment.
- Shackling during labor and postpartum may violate constitutional standards depending on the detainee’s security risk, medical risk, and officials’ awareness of medical restrictions; conflicting evidence on those points creates a triable issue.
- Denial of postpartum accommodations (such as access to a breast pump) can implicate serious medical needs, but deliberate indifference turns on the seriousness of the condition and the reasonableness of the response in light of the evidence.
- Municipal liability under § 1983 requires proof that a municipal policy, custom, or practice was the moving force behind the alleged constitutional violation; it cannot rest on respondeat superior.
- When evidence conflicts on how policies were applied in practice and whether they caused the alleged harm, Monell liability should not be resolved as a matter of law.

## Conclusion

The Sixth Circuit held that disputed facts concerning security justification, officers’ knowledge of medical restrictions, the extent of medical harm, and the implementation of municipal policies barred summary judgment for the detainee on both the labor-shackling and breast-pump claims, requiring remand for further proceedings.


Villegas v. Metro. Gov't of Nashville & Davidson Cnty., 709 F.3d 563 (6th Cir. 2013)