Whether the courts should employ the historically accepted two-prong deliberate indifference framework or the 'objective unreasonableness' analysis for inadequate medical care claims by pretrial detainees

QUESTION PRESENTED To successfully state a constitutional claim for inadequate medical care, a pretrial detainee must show that a correctional healthcare provider was deliberately indifferent to a serious medical condition. In such a case, should the courts employ the historically accepted two-prong deliberate indifference framework, consisting of both an objective component and a subjective state-of-mind component; or, instead, employ the “objective unreasonableness” analysis as first raised in Kingsley v. Hendrickson, 576 U.S. 389, 397, 135 S.Ct. 2466, 192 L.Ed.2d 416 (2015), despite the fact: (1) Kingsley’s holding was narrowly confined to the nature of the claim presented, excessive use of force; (2) Kingsley declined to address, let alone promote, the application of a new standard to deliberate indifference claims based upon inaction, such as allegedly inadequate medical care; and (8) an objective standard is unworkable and would only result in the constitutionalizing of a medical malpractice claim?