Whether the trial court and panel erred in failing to draw inferences in Grochowski's favor and find that the conditions and systems created a substantial risk of harm, and in granting qualified immunity and judgment for the County

Questions Presented. Jail supervisor policymakers and Clayton County, Georgia were sued by detainee Grochowski’s representatives for the known conditions and systems they controlled which caused an undetected in-cell assault in which Brooks, 20, killed Grochowski, 57, for Grochowski’s candy. Jail and cell door design prevented meaningful in cell observation by a central tower guard when the cell door was closed. The process systemically ignored a record of assaults in making the final housing assignment of the “Medium” detainees, where Brooks had two assaults and Grochowski none. Long-term County underfunding had caused inadequate jail staff, causing the Sheriff to close a 96 cell housing unit that could have been used to single cell assaultive or disruptive detainees, who, when put in these double cells, in this jail increased the already substantial risk of undetected assaults. Kinglsey v. Hendrickson, 576 U.S. 389 (2015), as applied in three other circuits, would apply an objective reasonableness test to remediate the conditions and systems creating a substantial risk of harm to Clayton detainees. 1. Did the trial court and panel failed to draw inferences in Grochowski’s favor erroneously finding each condition did not present a substantial risk of harm, and by failing to consider the combination of the conditions, erroneously granting the jail supervisors qualified immunity and the County judgment, finding the conditions did not pose a substantial risk? 2. Should Kingsley’s objective reasonableness test apply to the conditions and systems creating an unreasonable risk of harm to detainees, warranting denial of summary judgment? 3. Should legislative immunity shield a County representative from a deposition? i