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MICHAEL SOUTHARD,
Plaintiff-Appellee,
v.
NEWCOMB OIL COMPANY, LLC,
Defendant-Appellant.
   No. 20-5318
Appeal from the United States District Court
for the Western District of Kentucky at Louisville.
No. 3:18-cv-00803—Charles R. Simpson, III, District Judge.
Argued: June 11, 2021
Decided and Filed: August 4, 2021
Before: COLE, BUSH, and NALBANDIAN, Circuit Judges.


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OPINION
_________________________

COLE, Circuit Judge. To use the Federal Arbitration Act to enforce an arbitration agreement, a party must have entered an arbitration agreement. This admittedly tautological principle resolves the first part of this case. An equally fundamental principle resolves the second part: declining to exercise supplemental jurisdiction over an action with no remaining federal claims is not an abuse of discretion. We affirm.



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SAMANTHA BURWELL, as Personal Representative for the Estate of Christopher Phillips,
Plaintiff-Appellant,
v.
CITY OF LANSING, MICHIGAN, a municipal entity; SERGEANT RODNEY CHRISTOPHER ANDERSON, DETENTION OFFICER LANA HADZAJILIC LISKIEWICZ, DETENTION OFFICER BRIAN LEIGH KELLEY, DETENTION OFFICER MELISSA ANN OUDERKIRK, and LORRIE JANE RIDENOUR, in their individual and official capacities,
Defendants-Appellees.
   No. 20-1505
Appeal from the United States District Court
for the Western District of Michigan at Grand Rapids.
No. 1:17-cv-00813—Janet T. Neff, District Judge.
Argued: March 4, 2021
Decided and Filed: August 4, 2021
Before: GIBBONS, WHITE, and THAPAR, Circuit Judges.


_________________________
OPINION
_________________________

JULIA SMITH GIBBONS, Circuit Judge. Christopher Phillips was arrested for driving on a suspended license and booked into the Lansing City Jail. Three hours later he was discovered unconscious in a pool of vomit and pronounced dead of a drug overdose. Although numerous officers were tasked with monitoring Phillips’s wellbeing, they admittedly failed to follow jail procedures designed to prevent these sorts of tragedies. For some of the officers, their negligence in monitoring Phillips insulates them from liability in this deliberate indifference action, which requires subjective knowledge and conscious disregard of a detainee’s serious medical needs. But a jury could conclude that one officer, Brian Kelley, had the requisite state of mind for liability. As to Kelley only, we reverse the district court’s grant of summary judgment. We affirm the district court’s grant of summary judgment to the remaining defendants, as well as the grant of summary judgment to all the defendants on the state law gross negligence claim because the plaintiff failed to demonstrate a triable issue on causation.