AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law for Jails, Prisons and Detention Facilities
were not liable for failing to prevent pre-trial detainee's suicide. They
had no reason to know that she was likely to kill herself, since she had
not previously threatened or attempted to do so, and the mere fact of her
intoxication, standing alone, was insufficient to put them on notice of
the risk of suicide, particularly when she had been detained on previous
occasions for public intoxication without incident. Cruise v. Marino, No.
3:01-2310, 404 F. Supp. 2d 656 (M.D. Pa. 2005). [N/R]
County sheriff was entitled to qualified immunity from personal liability for failing to prevent pretrial detainee suicides at the jail, given that there was no evidence indicating that he was personally aware that detainees previously had considered suicide, and there was also no evidence that he personally directed any actions concerning the detainees during their detention. Mann v. Lopez, No. Civ.A. SA05CA0527, 404 F. Supp. 2d 932 (W.D. Tex. 2005). [N/R]
County and sheriff were not liable for detainee's suicide when the jail had procedures in place to screen detainees for suicidal tendencies and the detainee showed no signs of any suicidal intentions during three weeks of detention prior to killing himself. Keehner v. Dunn, No. 05-2136, 409 F. Supp. 2d 1266 (D. Kan. 2005). [N/R]
Jailers did not act with deliberate indifference in failing to prevent detainee's suicide attempt when they based their actions on the opinion of a psychiatric doctor that the prisoner, in previously stabbing himself in the wrist and drinking cleaning solution, was not suicidal, but merely "acting out" and "malingering." Drake v. Koss, No. 05-1464, 2006 U.S. App. Lexis 5396 (8th Cir.). [2006 JB Apr]
Deputies who placed an intoxicated detainee who had made suicidal threats in a cell under video surveillance were not liable for his subsequent successful suicide despite failure to remove the shoelaces he used to hang himself. Short v. Smoot, No. 05-1284, 2006 U.S. App. Lexis 2564 (4th Cir.). County sheriff was not entitled to summary judgment on claims that he was individually liable for a jail detainee's suicide on the basis of failure to train personnel on the risk of detainee suicide. Gaston v. Ploeger, No. 04-2368, 399 F. Supp. 2d 1211 (D. Kan. 2005). [2006 JB Mar]
Facts alleged were sufficient to create a genuine issue as to whether an officer was deliberately indifferent to a "strong likelihood" that a DUI arrestee would commit suicide while in the city jail. Snow v. City of Citronelle, No. 04-14409, 2005 U.S. App. Lexis 17243 (11th Cir.). [2005 JB Oct]
Allegedly suicide-prone prisoner failed to show a causal connection between the pending execution of another inmate and the alleged increased risk that he and other suicide-prone prisoners might attempt to harm themselves. Trial court properly dismissed his lawsuit, which he sought to bring as a class action on behalf of suicide-prone prisoners, seeking to bar the execution. Ziemba v. Rell, No. 05-8903, 409 F.3d 553 (2nd Cir. 2005). [N/R]
Prison officials did not show deliberate indifference to the serious needs of a mentally ill and suicidal prisoner by failing to provide requested therapeutic art supplies, when they did provide a medical examination and anti-psychotic medications. Scarver v. Litscher, No.01C497, 371 S. Supp. 2d 986 (W.D. Wis. 2005). [N/R]
If officers waited ten minutes to summon medical assistance after discovering that arrestee had hung himself in his cell, this could be found to be deliberate indifference, serving as a basis for liability for his death. Bradich v. City of Chicago, No. 04-3626, 2005 U.S. App. Lexis 13131(7th Cir.). [2005 JB Aug]
Sheriff and jail administrator could not be held liable for detainee's suicide in the absence of any evidence that either of them was aware of a conversation the detainee's spouse had with a correctional officer concerning the risk that he might attempt suicide or another officer's report that the detainee may have been trying to accumulate some of his medications to use at a later time. Court also finds that jail's suicide prevention policy was reasonable and that the county was not deliberately indifferent to training its employees in the prevention of suicide. The fact that the policy had not been "updated" recently, and that jail was not accredited by the American Correctional Association (ACA), did not alter the result when the policy contained a detailed listing of factors for the identification of possibly suicidal prisoners, procedures for screening inmates, and required that personnel receive on-going training in suicide prevention and intervention. Harvey v. County of Ward, No. A1-03-135, 352 F. Supp. 2d 1003 (D.N.D. 2005). [N/R]
Federal trial court properly granted judgment as a matter of law on federal civil rights claims and negligent training and supervision claims against Florida sheriff arising out of detainee's suicide after his requests to see a psychiatrist failed to be granted. Appeals court finds, however, that the trial court erred in also granting judgment for the sheriff on a state law vicarious liability negligence claim. Trial court acted within its discretion in excluding evidence of other suicides at detention facility, and testimony of plaintiff's suicide expert witness. Cook v. Sheriff of Monroe County, No. 03-14784, 2005 U.S. App. Lexis 4014 (11th Cir. 2005). [2005 JB May]
Alleged county jail policy of keeping all pretrial detainees housed in administrative segregation completely naked violated their due process and Fourth Amendment rights, and was not justified by concerns about suicide and guard safety. Federal court was also troubled by the use of guards of the opposite gender to remove clothing from such detainees. Sheriff was, however, entitled to qualified immunity from liability, as the law on the subject was not clearly established at the time the alleged policy was implemented. Rose v. Saginaw County, #01-10337, 353 F. Supp. 2d 900 (E.D. Mich. 2005). [2005 JB May]
City and police officer were not liable for suicide of pre-trial detainee in his cell when officer did not know that the detainee was suicidal and the city had constitutionally adequate suicide prevention policies. Gray v. City of Detroit, No. 03-2515, 2005 U.S. App. Lexis 3419 (6th Cir. 2005). [2005 JB Apr]
Police officer working as jailer in city jail was not entitled to peace-officer immunity under Alabama State law on a claim against him by the sister of an inmate who committed suicide there. The officer allegedly failed to follow mandatory rules and procedures requiring him to check on the prisoner twice an hour, and therefore was not exercising discretion when he engaged in the conduct that allegedly led to the inmate's death. Court rejects, however, claims against police chief based on training, implementing and enforcing procedures concerning the identification and handling of potentially suicidal prisoners. Howard v. City of Atmore, No. 1021312, 887 So.2d 201 (Ala. 2003), as modified on denial of rehearing (2004). [N/R]
County, warden, and jail personnel had no liability for pre-trial detainee's suicide when there was nothing which would have put them on notice that he was particularly susceptible to suicide attempts. Woloszyn v. Lawrence, No. 03-2390, 2005 U.S. App. Lexis 1417 (3d Cir.). [2005 JB Mar]
Juvenile pre-trial detainee's rights were not violated by his incarceration in adult county jail when it was done in compliance with Michigan state law and he was kept segregated from adult prisoners. Conditions he faced in lock-down were not punitive but were justified by a legitimate interest in preventing his possible suicide. Federal appeals court further finds that his due process rights were not violated by his loss of credit in alternative education program following his arrest and detention or by the program's refusal to re-enroll him after his release. Daniels v. Woodside, No. 03-2053, 2005 U.S. App. Lexis 1127 (6th Cir.). [2005 JB Mar]
Sheriff was not entitled to qualified immunity to claim that he was deliberately indifferent in his training and supervision of personnel in dealing with the risk of suicide in a county jail where two prior suicides had occurred. Detainee who threatened suicide was allegedly placed in an isolation cell and given a blanket with which he hung himself a half hour after making the threat. Wever v. Lincoln County, No. 03-3633, 2004 U.S. App. Lexis 22974 (8th Cir. 2004). [2004 JB Dec]
Jail personnel were not deliberately indifferent to a substantial risk of injury or death for pretrial detainee subsequently found dead in her cell either from self-hanging or from strangulation by another person. There were no prior signs that the detainee, arrested for allegedly operating a vehicle under the influence of drugs, was suicidal and there was no information from which they would have known that she was at risk of harm by someone else, and no evidence that the jailers themselves murdered her. Stiltner v. Crouse, No. 1:03 CV 00078, 327 F. Supp. 2d 667 (W.D.Va. 2004). [N/R]
Deliberate indifference to the risk that a detainee in a county jail would commit suicide was not shown where the jailer removed shoes and socks from the detainee's cell, had him placed in a padded "lunacy cell," and instructed personnel to place him on a suicide watch. Additionally, when the detainee was subsequently observed in the cell without clothes and in a "frog-like" position, a nurse was instructed to observe the detainee to assist in determining whether the cell should be entered, and it was concluded that the detainee was merely sleeping at the time. The fact that this conclusion was incorrect might show negligence, but not the deliberate indifference required for a civil rights claim. Gray v. Tunica County, Mississippi, #03-60761, 100 Fed. Appx. 281 (5th Cir. 2004). [N/R]
Federal appeals court reinstates claim against county sheriff for failing to protect detainee against risk of suicide after he learned that he had just made a suicide attempt at another jail from which he had been transferred. Sheriff allegedly failed to inquire into the details of this prior attempt and placed the prisoner in a cell with a bedsheet with which the prisoner successfully killed himself. The prior suicide attempt days before had also involved the use of a bedsheet. Turney v. Waterbury, No. 03-2375, 2004 U.S. App. Lexis 14811 (8th Cir). [2004 JB Sep]
Prison psychiatrist and mental health worker did not act with deliberate indifference in returning prisoner, formerly found to be suicidal, to the general prison population, after which he successfully killed himself. The prisoner, at the time, appeared to have responded positively to the medication provided, and signed a contract in which he agreed not to hurt himself or others. The court finds that there was nothing from which the defendants could have inferred a strong likelihood that he would commit suicide at that time. Soles v. Ingham County, 316 F. Supp. 2d 536 (W.D. Mich. 2004). [N/R]
Alleged failure of correctional employees to attempt to resuscitate an inmate found hanging in his cell did not violate any clearly established constitutional right in the absence of any evidence that the inmate had a pulse or was breathing at the time a corrections officer arrived at the cell. Dipace v. Goord, 308 F. Supp. 2d 274 (S.D.N.Y. 2004). [N/R]
Federal appeals court upholds wrongful death jury award of $1.75 million in Illinois detainee suicide case based on alleged custom of failing to follow proper procedures with mentally ill inmates. Woodward v. Corr. Med. Services of Illinois, #03-3147, 2004 U.S. App. Lexis 9537 (7th Cir.). [2004 JB Jul]
Pre-trial detainee's prior placement on suicide watch, and other prior incidents, including him cutting himself, did not suffice to show that jail officials were deliberately indifferent to the possibility of his attempting suicide by placing him in the general population, when a medical judgment had been made that this was now appropriate. There was nothing to show that jail officials were subjectively aware of a substantial risk that the detainee would imminently attempt suicide. Detainee therefore could not seek damages for injuries suffered in unsuccessful suicide attempt. Strickler v. McCord, 306 F. Supp. 2d 818 (N.D. Ind. 2004). [N/R]
Claim that jail personnel who came into contact with a pre-trial detainee "should have" known that she was suicidal was not sufficient to state a claim for "deliberate indifference" to a known substantial risk of suicide as required for federal civil rights liability. House v. County of Macomb, 303 F. Supp. 2d 850 (E.D. Mich. 2004). [N/R]
Jailer who decided to finish feeding other inmates rather than immediately checking on pretrial detainee he observed lying nude and apparently sleeping in a "peculiar" position was entitled to qualified immunity from liability for prisoner's successful suicide. The detainee's use of his jail jumpsuit to strangle himself was not foreseeable and the cell was padded, lacking fixtures that could be used by a prisoner seeking to hang himself. Gray v. Tunica County, Mississippi, 279 F. Supp. 2d 789 (N.D. Miss. 2003). [N/R]
Detainee's action of hanging himself to death with shoelace in his holding cell less than two hours after being placed there on DUI charges did not subject facility to liability under Pennsylvania state law for negligence. Neither "personal property" nor "real estate" exceptions to sovereign immunity under state law applied. Pennsylvania State Police v. Klimek, 839 A.2d 1173 (Pa. Cmwlth. 2003). [2004 JB Apr]
Private psychiatric hospital and not-for-profit company which owned it were not immune under Tennessee law for potential liability for county jail inmate's suicide on the basis of their employee's alleged action in telling county jail that suicide protocol precautions were not necessary for this prisoner. Employee also qualified as a "state employee" because of his service in screening prisoners to determine if hospitalization was appropriate, and as a state employee, he was entitled to statutory immunity, but this did not alter the result as to the hospital or its owner. Shelburne v. Frontier Health, 126 S.W.3d 838 (Tenn. 2003). [N/R]
Georgia county correctional facility personnel took steps to monitor prisoner known to be a suicide risk after he previously attempted to harm himself and were not liable for his successful suicide in his cell which he accomplished by "unique methods," fashioning a tourniquet from a bed sheet and a crutch he had in his cell which he needed to walk after he broke his leg. Middlebrooks v. Bibb County, 582 S.E.2d 539 (Ga. App. 2003). [2004 JB Mar]
Federal trial judge upholds jury's finding that jail officials were negligent under Kansas state law, but not deliberately indifferent, as required for a federal civil rights claim, in failing to prevent the successful suicide of a inmate who used an electrical switchplate in his cell as a suicide aid. Jury's award of $10,002,000 in damages is reduced to $252,000 because of state statutory limit on wrongful death damage awards. Estate of Sisk v. Manzanares, 270 F. Supp. 2d 1265 (D. Kan. 2003). [2003 JB Dec]
Correctional officer could be found to have acted with deliberate indifference to an inmate's suicide threat if he actually, as alleged, responded to the threat by encouraging him to go ahead, leaving the area for a time, and refusing to return when other inmates tried to inform him of the inmate's hanging himself. Olson v. Bloomberg, No. 02-1874, 339 F.3d 730 (8th Cir. 2003). [2003 JB Nov]
Jail's failure to provide a second nighttime jailer, even if it violated the provisions of an earlier consent decree concerning jail conditions did not establish a violation of the rights of a pretrial detainee who committed suicide during night hours when only one jailer was on duty. Sole jailer did not act with deliberate indifference to the needs of the detainee, who had allegedly expressly threatened suicide, by waiting for approximately one hour and 46 minutes between conducting checks of the prisoner's cells. Cagle v. Sutherland, No. 02-13131, 334 F.3d 980 (11th Cir. 2003). [2003 JB Nov]
Prisoner's failure to object, in the trial court, to a magistrate's report and recommendations resulting in the dismissal of his claims that correctional officials were deliberately indifferent to his suicide attempts by allowing him to possess and swallow razor blades, barred his arguing any of his claims on appeal. Bacon v. McGarry, No. 02-4194, 71 Fed. Appx. 19 (10th Cir. 2003). [N/R]
Manufacturer of paper gown allegedly marketed for use with suicidal prisoners could be held liable when it failed to tear away when detainee hanged himself with it. Claims for products liability, negligence, and breach of warranty could proceed, along with due process claims against city for alleged reckless failure to provide proper medical care for suicidal prisoner. Court dismisses Eighth Amendment claim as inapplicable for the death of a pretrial detainee, as opposed to a convicted prisoner. Reed v. City of Chicago, No. 01C7865, 263 F. Supp. 2d 1123 (N.D. Ill. 2002). [2003 JB Oct]
County and county sheriff reach $300,000 settlement with family of jail inmate on their claim that his needs for psychiatric counseling were ignored, leading to his successful suicide. Lawsuit contended that the jail staff had knowledge that the prisoner had suicidal tendencies and had been diagnosed as a manic-depressive schizophrenic, but failed to make arrangements to provide mental health care. Estate of Price v. Black Hawk County, No. 00-CV-2008 (N.D. Iowa March 21, 2003), reported in The National Law Journal, p. B2 (April 7, 2003). [N/R]
Jail inmate's suicide was an unforeseen incident which could not be shown to have taken place because of the failure of officers to regularly conduct surveillance of his cell, when he acted "calm and controlled" before he took his own life, and his behavior did not show that he might be a danger to himself. Harvey v. Nichols, No. A03A0568, 581 S.E.2d 272 (Ga. App. 2003). [2003 JB Sep]
Montana Supreme Court finds that prison's practice of subjecting certain inmates to behavior modification plans, along with the living conditions in the areas where such inmates were housed, violated the state constitutional right to "human dignity" of mentally ill prisoner and represented cruel and unusual punishment, especially when used as a substitute for medical treatment for disruptive and suicidal prisoner. Walker v. State of Montana, #01-528, 68 P.3d 872 (Mont. 2003). [2003 JB Aug]
Parents of Mississippi inmate who committed suicide while incarcerated in county detention facility could not, under state law, pursue wrongful death lawsuit against defendant correctional officials when they were acting within the scope of their authority. State statute, A.M.C. Sec. 11-46-9(1)(m) prohibits inmate's negligence lawsuits against governmental entities and government employees acting within the scope of their authority, and the prisoner's parents "stood in the position" of the inmate in attempting to pursue a claim for wrongful death. Webb v. Desoto County, #2002-CA-00005-SCT, 843 So. 2d 682 (Miss. 2003). [N/R]
Estate of prisoner who died from a prescription drug overdose state a possible claim for negligence by alleging that prison personnel violated policies requiring controlled substance medication to be administered by licensed personnel, and by failing to complete a timely "unusual incident report" (UIR) concerning the prisoner's suicide attempt. Arias v. State of New York, Claim No. 97942, 755 N.Y.S.2d 223 (Ct. Cl. 2003). [N/R]
Correctional officials' interest in preventing suicide and preserving life, as well as maintaining order and discipline, outweighed a hunger-striking prisoner's right to privacy, resulting in a right to force-feed the prisoner. People ex. Rel. Department of Corrections v. Millard, Nos. 4-01-0857, 782 N.E.2d 966 (Ill. App. 2003). [2003 JB May]
Estate of manic-depressive schizophrenic prisoner with prior suicidal tendencies who committed suicide in his cell when left unattended reaches $300,000 settlement on federal civil rights lawsuit against sheriff and county. The plaintiff claimed that the decedent's need for psychiatric treatment or counseling was ignored, while the defendants argued that the decedent did not indicate a need for such care, but instead misled jail personnel about his medical history. Estate of Price v. Black Hawk County, No. 00-CV-2008 (March 21, 2003, N.D. Iowa), reported in The National Law Journal, p. B2 (April 7, 2003). [N/R]
Federal jury awards $1.75 million to the family of county jail detainee who hung himself after telling jail medical workers that he was suicidal. Jury award imposes liability on company that contracted with county to provide medical services at facility, as well as against social worker. County settled claims against it for $60,000 prior to trial. Woodward v. Correctional Medical Services, No. 00C6010, U.S. District Ct. N.D. Ill., Feb. 24, 2003, reported in Chicago Tribune, Sec. 2, page 3 (Feb. 25, 2003) and Chicago Daily Law Bulletin, p. 3 (Feb. 25, 2003). [2003 JB Apr]
The fact that a city's policy on monitoring suicidal pre-trial detainees allowed the clerk doing so to perform other duties at the same time did not, by itself, demonstrate deliberate indifference to the risk of harm, nor did the fact that the video equipment used for monitoring in this particular instance turned out to be defective. Serafin v. City of Johnstown, #02-1281, 53 Fed. Appx. 211 (3rd Cir. 2002). [2003 JB Apr]
Lawsuit for wrongful death based on prisoner's suicide which named health care provider as a defendant did not have to comply with medical malpractice lawsuit requirement of submission of an expert affidavit of merit. Correctional officers who allegedly failed to follow jail policies for monitoring and inspecting the prisoner's cell were not protected by qualified immunity from wrongful death action, as their duty of inspecting the cells on a schedule was "clear and certain," rather than requiring the exercise of personal judgment. Clark v. Prison Health Services, Inc., #A02A1014, 372 S.E.2d 342 (Ga. App. 2002). [N/R]
Dismissal in federal court of wrongful death lawsuit brought over detainee's action of hanging himself in county jail barred relitigation of the estate's wrongful death and negligence claims in state court. Quinn v. Estate of Jones, No. 2000-CA-00977-SCT, 818 So. 2d 1148 (Miss. 2002). [N/R]
Prison medical personnel were not deliberately indifferent to the needs of an inmate who committed suicide, when prisoner's condition was changeable and he sometimes appeared able to interact appropriately with others. Pelletier v. Magnusson, 201 F. Supp. 2d 148 (D. Maine 2002). [2002 JB Oct]
Federal civil rights lawsuit brought by inmate's estate more than two years after his suicide in a county jail was time-barred by a Kansas two year statute of limitations. The time period began to run after the sheriff showed the administrators an air vent similar to that from which the inmate hanged himself and told them that two other similar deaths had occurred, which had led him to consider placing covers over the vents, which he did not do. The court rejected the argument that the grief of the inmate's parents over his death tolled (extended) the two year time limit. Hanchett v. Saline County Board of Commissioners, 194 F. Supp. 2d 1150 (D. Kan. 2001). [N/R]
County was not liable to detainee's suicide in jail on the basis of alleged inadequately staffing when it had an effective policy of checking on suicidal inmates every fifteen minutes and an officer saw and spoke to the detainee 15 to 20 minutes prior to the time he was found hanging in his cell. Rapier v. Kankakee County, Illinois, 203 F. Supp. 2d 978 (C.D. Ill. 2002). [2002 JB Sep]
Jailer's alleged awareness of detainee's prior suicide attempt seven months before was not sufficient, standing alone, to impose liability for detainee's successful suicide, in the absence of any indication that there was a strong likelihood that the detainee would commit suicide when he did. Holland v. City of Atmore, 168 F. Supp. 2d 1303 (S.D. Ala. 2001). [N/R]
Prisoner's estate had a possible claim against prison psychologist for failing to take action to prevent prisoner's suicide when psychologist himself had previously decided that the prisoner was suicidal "enough" to be placed under close observation. Prisoner's own assertion that he was "not suicidal" when released from suicide watch after a day was insufficient to change the result. Comstock v. McCrary, #99-2448, 273 F.3d 693 (6th Cir. 2001). [2002 JB Apr]
Prison medical personnel could not be held liable for failure to prevent a mentally ill prisoner's suicide, but federal appeals court finds that a claim was adequately stated against correctional officers to whom the prisoner purportedly made statements about killing himself and who allegedly did not look inside his cell for five hours on the night he did so, despite his cell window being covered by toilet paper. Sanville v. McCaughtry, #00-2933, 266 F.3d 724 (7th Cir. 2001). [2002 JB Apr]
Kentucky county was entitled to sovereign immunity against claims for negligent operation of jail arising from prisoner's suicide in which he hung himself with a belt from the showerhead in his cell. State Board of Claims accordingly had no jurisdiction over claims brought by prisoner's estate against jailer and deputy jailers. Commonwealth v. Harris, No. 2000-SC-0409-TG, 59 S.W.2d 896 (Ky. 2001). [N/R]
Texas county juvenile detention facility reaches $100,000 settlement in lawsuit brought by family of 15-year-old who hung himself in his cell with a sheet. Creel v. Denton County, Denton Co., Texas, Cir. Ct., October 5, 2001, reported in The National Law Journal, p. B5 (Jan. 7, 2002). [N/R]
County sheriff's statement to the media that a jailor was watching a tv monitor and saw a pretrial detainee put a sheet around his neck was not admissible evidence in a lawsuit over the detainee's suicide. The statement did not come under a public records and reports exception to the hearsay rule, since it was not the result of the jail's investigation.. Ellis v. Jamerson, 174 F. Supp. 2d 747 (E.D. Tenn. 2001). [N/R]
Police dispatcher/jailer on duty when arrestee committed suicide was not liable, in the absence of subjective knowledge that there was a strong likelihood that arrestee would make the attempt at that time. Arrestee's prior alleged history of suicide attempts, drug abuse and mental problems did not, by themselves, show such knowledge when she did not exhibit suicidal threats or actions on the day of her most recent incarceration. Bowens v. City of Atmore, 171 F. Supp. 2d 1244 (S.D. Ala. 2001). [N/R]
Sheriff was entitled to summary judgment in federal civil rights lawsuit brought by prisoner's mother after he committed suicide in jail. Naumoff v. Old, #99-2574, 167 F. Supp. 2d 1250 (D. Kan. 2001). [N/R]
Estate of 17-year-old male pretrial detainee who committed suicide in N.Y. county jail did not show that jail officials were "subjectively aware" that he posed a suicide risk, so no federal civil rights claim could be pursued for failure to prevent the death. Plaintiff could, however, pursue state law wrongful death/negligence claim. Rivera v. County of Westchester, 729 N.Y.S.2d 836 (Sup. 2001). [2002 JB Jan]
County jail had no duty to obtain medical records of detainee from county hospital which would have revealed that he was a suicide risk and had previously attempted to kill himself. In the absence of an awareness of this risk, officer's failure to conduct required half-hour cell checks did not constitute deliberate indifference to the risk of the detainee committing suicide, but a state law negligence claim based on this can be pursued. Hott v. Hennepin County, #00-3595, 260 F.3d 901 (8th Cir. 2001). [2002 JB Jan]
Jail officials were not deliberately indifferent to the risk of prisoner suicide simply because they failed to remove a coat hook from jail cells after a prior suicide at the jail took place by a prisoner hanging himself from a protruding light fixture. Pretrial detainee could not recover damages for brain injuries he received during his suicide attempt. Hofer v. City of Auburn, Alabama, 155 F. Supp. 2d 1308 (M.D. Ala. 2001). [N/R]
299:173 Supreme Court of Alaska rejects trial court jury instructions that state could not be held liable for prisoner's death if it was caused by his intentional suicide. Joseph v. State, No. S-8518, 26 P.3d 459 (Alaska 2001).
298:158 Nebraska state statute mandating parental notification of juvenile detention did not impose liability on county and sheriff's deputies, based on failure to do so, for juvenile's subsequent suicide after his release from custody. Claypool v. Hibberd, #S-99-1223, 626 N.W.2d 539 (Neb. 2001).
298:155 Trial judge's award of $1.8 million in damages for suicide of pre-trial detainee in federal jail overturned; suicide after six months of incarceration was not foreseeable when prisoner had no known prior history of suicide attempts or thoughts; award of $1.6 million for pain and suffering while hanging to death was excessive when no reasoning for the award was offered by the court. Jutzi- Johnson v. United States, #00-2411, 263 F.3d 753 (7th Cir. 2001).
294:90 Constant video surveillance of suicidal prisoner's cell was not "deliberate indifference" to the risk of him taking his life; correctional officials not liable for prisoner hanging himself with his shoelaces; no liability, under Virginia state law, for suicide in the absence of a showing that prisoner was of "unsound mind" when he took his own life. Brown v. Harris, No. 00-1127, 240 F.3d 383 (4th Cir. 2001).
295:108 Michigan city reaches $31,500 settlement with three detainees jailed completely naked for a number of hours as a suicide prevention measure; prior court ruling found that removal of their underwear and possible viewing of their bodies by female officers was not adequately justified by suicide prevention concerns, and could violate privacy and due process rights. Wilson v. City of Kalamazoo,127 F. Supp. 2d 855 (W.D. Mich. 2000).
294:91 Having male pretrial detainees strip to their underwear as a suicide prevention measure if they refused to answer intake questions about suicidal tendencies was reasonable and did not violate their due process or privacy rights, even if done in the presence of female correctional officers. Johnson v. City of Kalamazoo, 124 F. Supp. 2d 1099 (W.D. Mich. 2000).
290:24 Sheriff and chief deputy were not entitled to qualified immunity in lawsuit over prisoner's successful suicide when they knew of her prior suicide attempt and of another prisoner's successful suicide in the same cell, which had a "blind spot" not viewable from a control room and several places from which a prisoner could tie a sheet to hang herself. Jacobs v. West Feliciana Sheriff's Dept., No. 99-30185, 228 F.3d 388 (5th Cir. 2000).
290:23 County policies were adequate to bar liability for prisoner's successful suicide; appeals court points to training program and American Correctional Association accreditation of jail. Yellow Horse v. Pennington County, Nos. 99-2419, 99-2420, 225 F.3d 923 (8th Cir. 2000).
289:10 "Low-level" county jail employees were not liable for prisoner's suicide after he was taken off of suicide watch, since they relied on statements by a nurse and a social worker that the prisoner no longer seemed suicidal; court orders further proceedings, however, on whether county policy, which did not require consulting with a mental health professional before ending suicide watch, was inadequate. Cills, Estate of, v. Kaftan, 105 F. Supp. 2d 391 (D.N.J. 2000).
281:73 Federal government liable for $1.8 million for suicide of pre-trial detainee, based on repeated failure to respond to signs that he might be suicidal; trial judge finds that policies and training programs were in place to help officers identify and aid suicidal prisoners, but these policies were not followed. Jutzi-Johnson v. U.S., No. 96-C-5708, U.S. Dist. Ct., N.D. Ill. March 29, 2000, reported in The Chicago Daily Law Bulletin, p. 1 (March 30, 2000).
281:74 Jail employees and officials were not liable for mentally ill detainee's death from asphyxiation which was either suicide or an accidental death caused by his illness; while jail personnel may have been negligent in how they treated this detainee, their conduct did not rise to the level of "deliberate indifference" required for federal civil rights liability. Thornton v. City of Montgomery, 78 F. Supp. 2d 1218 (M.D. Ala. 1999).
282:91 Alleged failure to train jail personnel in suicide prevention was not the proximate cause of prisoner's death when nothing gave jail personnel notice that he might be suicidal; decedent's own mother, a trained psychologist, believed that he was not suicidal; factual dispute over whether one jailor saw the noose being tied but failed to act immediately justified denial of summary judgment on the claims against him. Ellis v. Washington County, No. 98- 6178, 198 F.3d 225 (6th Cir. 1999).
283:107 Incident during an arrest three years before, during which detainee tried to swallow a crack pipe and crack cocaine, was insufficient to put jailers on notice that he had present suicidal tendencies; defendant jail officials were entitled to qualified immunity on lawsuit over failure to prevent detainee's suicide. Lambert v. City of Dumas, No. 99-1081, 187 F.3d 931 (8th Cir. 1999).
279:41 Prison psychiatrists were not liable for prisoner's suicide by overdosing on prescribed medication he hoarded, despite their purported knowledge of his suicidal thoughts and medicine hoarding at another facility; psychiatrists did not know that "pill line" procedures were insufficient to prevent such hoarding. Williams v. Mehra, No. 97-1118, 186 F.3d 685 (6th Cir. 1999).
266:25 Jailer, county and sheriff were not liable for prisoner's successful suicide in his cell; jailer correctly classified prisoner as suicide risk and took several steps to attempt to prevent suicide, and county and sheriff had policies in place designed to try to prevent inmate suicide. Liebe v. Norton, #98-1163, 157 F.3d 574 (8th Cir. 1998).
273:140 Prison classification specialist and segregation unit supervisor without specific knowledge of prisoner's prior alleged suicide attempt were not liable for failure to prevent his successful suicide; prison clinical psychologist who failed to place prisoner on suicide watch, but instead referred him to psychiatrist for further evaluation did not act with deliberate indifference to serious medical needs. Greffey v. State of Ala. Dept. of Corrections, 996 F.Supp. 1368 (S.D. Ala. 1998).
274:154 Co. and county psychiatrist were not liable for detainee's successful suicide after his release from custody; placing detainee on suicide watch and taking steps to encourage him to agree to take his medication for paranoid schizophrenia did not constitute deliberate indifference. Collignon v. Milwaukee Co., #98-1711, 163 F.3d 982 (7th Cir. 1998).
260:124 Update: Officers were entitled to qualified immunity in prisoner suicide case where they removed shoes with laces, made sure detainee did not have a belt, and also took steps to ensure that detainee could not harm herself with blanket and instructed that a close watch be placed on her; detainee's right to be free from deliberate indifference to suicide risk was "clearly established," but officers acted objectively reasonably. Hare v. City of Corinth, 135 F.3d 320 (5th Cir. 1998).
[N/R] Illinois Tort Immunity Act did not protect sheriff against allegation that he had knowledge that conditions in city jail created a substantial risk of harm to an arrestee, but still ordered deputy to place arrestee, who subsequently committed suicide, in city jail. Payne v. Churchich, No. 97-3344, 161 F.3d 1030 (7th Cir. 1998).
255:42 Officers were not "deliberately indifferent" to risk of suicide by detainee experiencing heroin withdrawal; no signs of suicidal tendencies prior to detainee's suicide. Richardson v. Dailey, 675 N.E.2d 787 (Mass. 1997).
258:89 City was not liable for death of intoxicated arrestee who hung himself in his cell with his jeans; officers acted within the scope of their employment, and performed a discretionary act in good faith in failing to determine that the arrestee was a suicide risk; arrestee's threat to kill himself was only heard by his cellmate and not by officers, who were not in the cell area. Galveston, City of, v. Burns, 949 S.W.2d 881 (Tex. App. 1997).
[N/R] Private doctors and mental health providers were not entitled to qualified immunity from lawsuit based on prisoner's suicide; they were acting as private parties motivated by desire for profit, rather than as governmental agents. McDuffie v. Hopper, 982 F.Supp. 817 (M.D. Ala. 1997).
241:10 Correct legal standard for liability on prisoner suicide was not whether jail officers "knew or should have known" of prisoner's suicide risk, but rather whether they had "actual knowledge of the substantial risk" and responded with "deliberate indifference." Hare v. City of Corinth, 74 F.3d 633 (5th Cir. 1996).
243:41 Prisoner diagnosed as potential suicide risk by medical personnel and prescribed psychotropic drugs stated a claim for deliberate indifference to serious medical needs by asserting that psychiatrist at facility he was transferred to discontinued his medication without evaluating him or reviewing medical records. Steel v. Shah, 87 F.3d 1266 (11th Cir. 1996).
245:75 Doctor's classification of pretrial detainee as "potentially suicidal," rather than "high risk" for suicide was exercise of professional medical judgment and doctor was not liable for detainee's subsequent successful suicide, since no deliberate indifference was shown. Cole, Estate of, by Pardue v. Fromm, 94 F.3d 254 (7th Cir. 1996).
[N/R] Suicide of prisoner after suicide watch was called off might be the result of deliberate indifference, based on knowledge of prior suicidal behavior. Robey v. Chester Co., 946 F.Supp. 333 (E.D. Pa. 1996).
[N/R] Law enforcement defendants were entitled to qualified immunity in lawsuit over suicide of prisoner in city jail; no deliberate indifference was shown. Gay v. City of Daleville, 953 F.Supp. 1315 (M.D. Ala. 1996).
234:90 Prisoner's death from swallowing bar of soap was not foreseeable; federal trial court abused its discretion by overturning jury verdict for correctional defendants in civil rights/wrongful death lawsuit. Hardin v. Hayes, 52 F.3d 934 (11th Cir. 1995).
219:42 Jail employees were not entitled to qualified immunity in suit brought by family of detainee who killed herself in jail cell after making suicide threats to interviewing officer; detainee was placed in isolated cell and blanket with which she hung herself was left in cell. Hare v. City of Corinth, Ms., 36 F.3d 412 (5th Cir. 1994).
219:43 Juvenile prisoner who suffered permanent brain damage after hanging himself with a sheet awarded $600,000 in damages against county based on state-law negligence in failure to prevent suicide attempt; failure to take steps to prevent such attempts because of shortage of funds was no defense. Myers v. Co. of Lake, Ind., 30 F.3d 847 (7th Cir. 1994).
220:57 Mere fact that arrestee was intoxicated did not give detention center notice that there was a specific risk she would commit suicide; no "deliberate indifference" to serious medical needs was shown. Hocker, Estate of, v. Walsh, 22 F.3d 995 (10th Cir. 1994).
221:73 Alleged violation of federal statute in placing juvenile detainee in adult jail was not proximate cause of his suicide attempt; federal appeals court rejects argument that juvenile detainees, as a class, are specially susceptible to suicidal tendencies and therefore should be specially screened. Horn v. Madison Co. Fiscal Court, 22 F.3d 653 (6th Cir. 1994).
224:122 Individual jailers were not liable for pre-trial detainee's suicide in his cell when they did not know that he had suicidal tendencies; federal appeals court allows claim against city for alleged inadequate training of jailers to go forward, however. Irwin v. City of Hemet, 27 Cal.Rptr.2d 433 (Cal.App. 1994).
225:138 Co. was not liable for suicide of two prisoners in county jail when jail medical personnel did conduct some screening of prisoners, thus showing no "deliberate indifference" on part of county towards possible prisoner suicide. Tittle v. Jefferson Co. Com'n, 10 F.3d 1535 (11th Cir. en banc 1994).
225:138 Deputy sheriff's alleged statements to prisoner that his fiancee was having "sexual intercourse" with three men, which prisoner claimed drove him to suicide attempt, were insufficient to state claim for violation of constitutional rights. Parsons v. Bd. Cty. Com'rs Marshall Cty., Kan., 873 F.Supp. 542 (D. Kan. 1994).
226:155 Co. and state not entitled to prosecutorial immunity in wrongful death lawsuit brought by deceased prisoner's estate against county prosecutor for alleged failure to notify jail that medical report he received indicated that prisoner had suicidal tendencies. Smith v. Butte-Silver Bow Co., 878 P.2d 870 (Mont. 1994).
[N/R] Father, who was administrator of deceased son's estate, had standing, either as parent or as administrator, to sue correctional officials for damages for son's suicide while in custody. Frey v. City of Herculaneum, Mo., 37 F.3d 1290 (8th Cir. 1994).
Jury awards $500,000 to estate and surviving relatives of jail inmate who committed suicide while in custody; trial judge reduces $450,000 wrongful death portion of award to $100,000 because of a Massachusetts statutory limit on awards against governmental entities for wrongful death. Natriello v. Flynn, 837 F.Supp. 17 (D. Mass. 1993).
Co. was not liable for suicide of young detainee with brain damage and frequent past history of arrests; plaintiff failed to show that county policies led to detainee's suicide. Hood v. Itawamba Co., Mississippi, 819 F.Supp. 556 (N.D. Miss. 1993).
City liable for $237,204 for officers' failure to constantly monitor suicidal prisoner. Estate of Bragado v. City of Zion, U.S. Dist. Ct., N.D. Ill., reported in Chicago Daily Law Bulletin, p. 15 (Dec. 10, 1993).
City and officers were not liable for violation of civil rights for failing to prevent female detainee arrested for public intoxication from hanging herself in her cell with a garden hose used to wash down jail floors; detainee had not exhibited any suicidal tendencies; defendants might be liable, however, under state law for negligence. Evans v. City of Marlin, Tex., 986 F.2d 104 (5th Cir. 1993).
Texas appeals court orders new trial in jail suicide case; trial judge improperly excluded evidence of negligent training of jailers and negligent screening of prisoners for suicidal tendencies. Alvarado v. City of Brownsville, 865 S.W.2d 148 (Tex. App. 1993).
Deputies at county jail could be sued for failure to follow procedure requiring them to check frequently on suicidal prisoner, but city officers were not liable for making decision to transfer prisoner to county jail after he attempted suicide in city holding cell. Camps v. City of Warner Robins, 823 F.Supp. 724 (M.D. Ga. 1993).
$450,000 settlement in suit by estate of detainee who hung himself to death with long sock after officers prevented his attempt to hang himself with his shirt and left him alone in cell to call ambulance. Langton v. Town of Southington, U.S. Dist. Ct. D. Conn., Nos. 241CV00366 (PCD), 291CV00867 (PCD), Sept. 20, 1993, 37 ATLA L. Rep. 217 (Aug. 1994).
Family of suicidal intoxicated man who killed himself in county jail receives $325,000 settlement from county in wrongful death/civil rights lawsuit. Los Ang. Daily Jour. Verdicts & Settlements, p. 3 (March 25, 1994).
Co. and prison officials not liable for suicide of domestic violence pre-trial detainee with alcohol problems ten minutes after a mental health evaluation failed to find any suicidal tendencies. Herman v. Clearfield Co., Pa., 836 F.Supp. 1178 (W.D. Pa., 1993).
Juvenile detention center was not liable for suicide of thirteen-year-old who hung himself in his room using a bed sheet and a shoelace; no indication of suicidal intent was communicated to the center's personnel. Scott v. State, 618 So.2d 1053 (La. App. 1993).
Florida appeals court holds that question of whether a detainee's suicide attempt was foreseeable should have been decided at trial; suit by detainee who suffered brain damage after suicide attempt reinstated. Schmelz v. Sheriff of Monroe Co., 624 So.2d 298 (Fla. App. 1993).
No liability for jail employees for failing to prevent death of trustee prisoner who died from hanging during "auto-erotic asphyxiation"; officer who discovered hanging body was not deliberately indifferent in failing to attempt artificial resuscitation when he determined that prisoner was already dead. Reed v. Woodruff Co., Ark., 7 F.3d 808 (8th Cir. 1993).
Jury awards $500,000 to estate of jail prisoner who hung himself in his cell while under "suicide watch"; jail assigned other prisoner to watch prisoner under "suicide watch", and allegedly only offered eight hour training course for correctional officers. Natriello v. Flynn, U.S. Dist. Ct., D. Mass., No. 91-40158XX-NG, June 11, 1993, reported in 36 ATLA L. Rep. 368 (Dec. 1993).
Co. was not liable for jail detainee's suicide; detainee's shoelaces had previously been taken away, and it was an individual correctional officer's one-time decision to return the laces to him which allowed him to hang himself with them in his cell. Russell v. Knox Co., 826 F.Supp. 20 (D. Me. 1993).
Officer was not liable for detainee's death from hanging himself with suspenders officer failed to remove; order requiring removal of personal property was for the purpose of protecting all those in custody and did not impose a duty to the individual prisoner. Cooper v. Planthold, 857 S.W.2d 477 (Mo. App. E.D. 1993).
New Hampshire Supreme Court holds that detainee who unsuccessfully attempted suicide in jail can sue city for damages based on allegation that jailers knew of his prior suicide attempts while in custody, yet failed to take reasonable steps to prevent another attempt. Murdock v City of Keene, 623 A.2d 755 (N.H. 1993).
State Commission on Jail Standards was not liable for suicide of inmate at county jail it had previously cited for violation of its standards for adequate care for suicidal prisoners. Valles v. Texas Commission on Jail Standards, 845 S.W.2d 284 (Tex. App. 1992).
Mother of pretrial detainee who committed suicide could sue county for her own injuries allegedly resulting from deprivation of the detainee's constitutional rights, but evidence did not support a claim that the county had a policy of inadequate training of jail staff on the care of suicidal prisoners. Rhyne v. Henderson Co., 973 F.2d 386 (5th Cir. 1992).
Texas state law does not prohibit a wrongful death lawsuit against a county for a jail inmate's suicide while in custody. Mutrux v. Cameron Co., Texas, 809 F.Supp. 510 (S.D. Tex. 1992).
State was not liable for drug overdose suicide of female inmate who prison staff knew was depressed and suicidal, in absence of any evidence of how she obtained the drugs or expert testimony showing that prison staff's measures were not reasonable. Cockrum v. State, 843 S.W.2d 433 (Tenn. App. 1992).
City was not liable for successful suicide of DUI arrestee in the absence of any indication that he had a strong likelihood of taking his own life. Perkowski v. City of Detroit, 794 F.Supp. 223 (E.D. Mich. 1992).
Officer who left station, leaving detainee alone in the cell in which he then hung himself, was not "deliberately indifferent" to risk of suicide when detainee exhibited no signs of suicidal tendencies; city and police chief not liable for failure to offer formal training on suicide prevention when standard procedures required frequent observation of detainees and training would not have aided officer in classifying this detainee as suicide risk. Bowen v. City of Manchester, 966 F.2d 13 (1st Cir. 1992).
Co. was not liable for suicides of two jail inmates on the basis of alleged inadequate training of jail personnel, but might be liable on the basis of alleged "defective condition" of jail cells - an iron bar across each cell's window from which many suicide attempts were made. Tittle v. Jefferson Co. Commission, 966 F.2d 606 (11th Cir. 1992).
Officers were not entitled to qualified immunity in suit over detainee's suicide attempt; detainee's prior arrests and suicide threats raised a factual issue as to whether they actually knew of his suicidal condition and failed to take preventive action. Hall v. Ryan, 957 F.2d 402 (7th Cir. 1992).
Failure to prevent suicide attempt by prisoner on "suicide watch" who tried to hang himself five minutes after officer checked on him was, at most, negligence, and insufficient to establish a federal civil rights claim. Schmelz v. Monroe Co., 954 F.2d 1540 (11th Cir. 1992).
Neither city or individual jail officials were liable for failing to determine that DUI arrestee was a suicide risk or to prevent his suicide. Barber v. City of Salem, Ohio, 953 F.2d 232 (6th Cir. 1992).
Indiana state statute did not provide immunity from negligence claims arising from suicides of two pre-trial detainees. Tittle v. Mahan, 583 N.E.2d 796 (Ind. 1991).
New York court overturns $77,000 negligence award to family of 17-year-old detainee who hanged himself with his T-shirt only eleven minutes after being placed in a holding cell; detainee's conduct did not show suicidal tendencies. Moore v. City of Troy, 577 N.Y.S.2d 969 (A.D. 1992).
Court correctly refused to give jury instructions that would have based civil rights liability for jail suicide on negligent failure to detect suicidal intent or to prevent suicide. York v. City of Detroit, 438 Mich. 744, 475 N.W.2d 346 (1991). Co. and jail officials were not liable for detainee's jail suicide despite his earlier suicide attempt when incarcerated there three years before. Hinkfuss v. Shawano Co., 772 F.Supp. 1104 (E.D. Wis. 1991).
City and officers liable for $1.104 million for failure to prevent suicide of intoxicated detainee; city policy of inadequate training on suicide prevention established basis for municipal liability. Simmons v. City of Philadelphia, 947 F.2d 1042 (3rd Cir. 1991).
Co., sheriff and correctional officer were not liable for failing to prevent suicide of prisoner taken off of "suicide watch" after he told social worker he was "no longer" contemplating killing himself. Leshore v. Co. of Worcester, 945 F.2d 471 (1st Cir. 1991).
Failure to charge air vents, from which a prisoner had hung himself three years earlier, did not make jail officials liable for another prisoner's suicide when he hung himself from the same vents; further hearings ordered on whether delay in arraignment helped cause the death. Wayland v. City of Springdale, Ark., 933 F.2d 668 (8th Cir. 1991).
Officer's failure to turn on television camera to view holdover cell was not "deliberate indifference"; officers were not liable for failing to prevent prisoner's suicide. Christian v. Stanczak, 769 F.Supp. 317 (E.D. Mo. 1991).
Correctional officer may have been deliberately indifferent to mentally disturbed detainee's suicide, if she had specific knowledge of his suicide threats and of his behavior of headbanging. Elliott v. Cheshire Co., N.H., 940 F.2d 7 (1st Cir. 1991).
City was not liable for suicide of prisoner when jail authorities had no reason to anticipate that prisoner would attempt to kill himself. Popham v. City of Talladega, 582 So.2d 541 (Ala. 1991).
Prison officials were not entitled to qualified immunity for failing to prevent inmate's suicide after his anti-depression medication was abruptly discontinued. Greason v. Kemp, 891 F.2d 829 (11th Cir. 1990).
Two officers liable to family of detainee who hanged himself in jail after being taken into custody to prevent him killing himself; county and police chief were not liable for failure to train officers in suicide prevention. Buffington v. Baltimore Co., Md., 913 F.2d 113 (4th Cir. 1990, cert. denied, 111 S.Ct. 1106 (1991).
State has the right and duty to force feed prisoner who wanted to starve himself to death. Dept. of Public Welfare v. Kallinger, 580 A.2d 887 (Pa. Cmwlth. 1990).
City was not liable for suicide of detainee; even if hourly inspections required by jail manual had been conducted, suicide in detainee's first hour of incarceration would not have been prevented; city not required to provide training for psychological screening of detainees for suicidal tendencies. Burns v. City of Galveston, Texas, 905 F.2d 100 (5th Cir. 1990).
Failure to train jail personnel to screen detainees for suicidal tendencies rejected as basis for liability for detainee's suicide; standard procedures followed by jail personnel prior to suicide showed lack of deliberate indifference. Popham v. City of Talladega, 908 F.2d 1561 (11th Cir. 1990).
Officers were not liable for failure to remove intoxicated detainee's belt and shoelaces; entitled to qualified immunity for detainee's suicide. Belcher v. Oliver, 898 F.2d 32 (4th Cir. 1990).
Jury awards $175,000 to estate of intoxicated detainee, former mental patient, who hung himself in his cell with his underpants. Safian v. Village of Palatine, No. 84L 10056, Cook Co. Circuit Court, Chicago, Illinois, reported in Chicago Daily Law Bulletin, p. 3, July 31, 1990.
Sheriff and officers not liable for attempted suicide of intoxicated detainee after they violated jail policy by failing to remove his boot laces. Hamlin v. Kennebec Co. Sheriff's Dept., 728 F.Supp. 804 (D. Maine 1990).
City liable for failure to train officer in suicide prevention for detainees; officer also liable for negligence in suicide of intoxicated detainee. Simmons v. City of Philadelphia, 728 F.Supp. 352 (E.D. Pa. 1990).
Jail warden liable for punitive damages for ordering solitary confinement without precautions for suicidal prisoner. Lewis v. Parish of Terrebonne, 894 F.2d 142 (5th Cir. 1990).
Officers, city, not liable for suicide of pre-trial detainee, despite records of prior attempts and officers' failure to remove belt. Williams v. Borough of West Chester, Pa., 891 F.2d 458 (3rd Cir. 1989).
Jury awards $1 million to family of detainee who committed suicide in holding cell after arrest for public intoxication. Simmons, Estate of v. City of Philadelphia, No. 87-3258, U.S. District Court, Philadelphia, Pa., reported in Personal Injury Verdict Reviews, No. 26, P. 4 (Feb. 12, 1990).
Sheriff and jailor were entitled to qualified immunity on suit concerning prisoner's suicide, even though medical history sheet showed earlier suicide attempt. Rellergert v. Cape Girardieu Co., Mo., 724 F.Supp. 662 (E.D. Mo. 1989).
Municipality was not liable for detainee's suicide in jail cell on allegation of inadequate training of officers. Dorman v. District of Columbia, 888 F.2d 159 (D.C. Cir. 1989).
Police Chief was not liable for suicide of intoxicated prisoner in jail cell; no duty to install surveillance system. Capodagli v. Wilson, 536 N.E.2d 135 (Ill. App. 1989).
Man who tried to hang himself in jail receives $100,000 settlement on claim that officers should have taken away his belt. Driscoll v. City of Irvine, reported in Orange Co. Register, Santa Ana, Calif., July 7, 1989.
Supplying a safety razor to pretrial detainee who committed suicide did not show deliberate indifference; no liability for prisoner who hung himself. Boyd v. Harper, 702 F.Supp. 578 (E.D. Va. 1988).
Prison officials not liable for suicide by juvenile inmate who had made no prior threats. Edwards v. Gilbert, 867 F.2d 1271 (11th Cir. 1989).
Failure of jail officials to recognize scars on inmate as "suicide hesitation cuts" amounted only to negligence which could not make them liable for his suicide death. Freedman v. City of Allentown, Pa., 853 F.2d 111 (3d Cir. 1988).
Family of man who hung himself in jail to receive $196,700; was not placed in observation cell despite fashioning rope from shirt earlier. Albery v. City of Euclid, Cuyahoga Co. Common Pleas, reported in Cleveland Ohio Plain Dealer, November 30, 1988.
Mother of prisoner who starved himself to death could not recover damages from sheriff and director of corrections absent allegations of policy or personal involvement. Geter v. Wille, 846 F.2d 1352 (11th Cir. 1988).
Reckless indifference to a pretrial detainee's risk of suicide can support federal civil rights claim. Colburn v. Upper Darby Tp., 838 F.2d 663 (3d Cir. 1988).
City not liable for injuries detainee suffered when he plunged headfirst into toilet bowl. Gordon v. City of New York, 517 N.E.2d 1331 (N.Y. 1987).
Prison not liable when inmate hung himself; inmate's shirt was not "machinery" for purposes of tort claims act. Silva v. State, 745 P.2d 1160 (N.M. Ap. 1986).
Allegation that prisoner was placed in separate cell without supervision after repeated suicide threats stated claim for "indifference" to medical needs. Seiler v. City of Bethany, 746 P.2d 699 (Okla. App. 1987).
Allegation that officers knew of detainee's suicidal tendencies but failed to take precautions stated civil rights claim; supervisors could be held liable for failure to provide training or establish procedures for suicide prevention. Danese v. Asman, 670 F.Supp. 709 (E.D. Mich. 1987).
Officer's failure to remove belt of prisoner who used it to hang himself while violation of policy, was not constitutional violation. Gagne v. City of Galveston, 671 F.Supp. 1130 (S.D. Tex. 1987).
City could be liable for suicide of intoxicated pretrial detainee. Beddingfield v. City of Pulaski, Tennessee, 666 F.Supp. 1064 (M.D. Tenn. 1987).
Placing intoxicated arrestee in regular cell not a constitutional violation; no liability under federal law for suicide. Smith v. City of Westland, 404 N.W.2d 214 (Mich. App. 1986).
Failure to follow department rule in ministerial task does not preclude immunity. Gagne v. City of Galveston, 805 F.2d 558 (5th Cir. 1986).
Individuals liable for breaking rules and ignoring cries of suicide attempt. Miga v. City of Holyoke, 497 N.E.2d 1 (Mass. 1986).
Jail accused of not meeting standards. Tsosie v. San Juan Co., Deseret News, Salt Lake City, Utah 5/15/86. Allegations that understaffing and underfunding resulted in suicide states a civil rights claim. Strandell v. Jackson Co., Ill., 634 F.Supp. 824 (S.D. Ill. 1986).
Fifth Circuit reverses and allows claim based on allegations that a policy was responsible for suicide. Partridge v. Two Unknown Police Officers of Houston, 791 F.2d 1182 (5th Cir. 1986).
Court reverses $1 million judgment and finds no liability for not restraining loud arrestee. Gordon v. City of New York, 502 N.Y.S.2d 215 (A.D. 2 Dept. 1986).
One year statute of limitations for suicide by hanging. Maurice v. Stoddard, 496 N.Y.S.2d (A.D. 3 Dept. 1985).
On the third time hearing this case, court rules police chief not entitled to individual immunity from liability for jail hanging. Young v. City of Ann Arbor, 382 N.W.2d 785 (Mich. App. 1985).
Jail hanging results in $2.4 million award. Crime Control Digest, Vol. 20 No. 29, July 21, 1986; and the Detention Reporter, Number 33 July 1986.
Parents suit over son's suicide within 30 minutes of confinement to continue. Strandberg v. City of Helena, 791 F.2d 744 (9th Cir. 1986).
Judgment for $75,000 against state reversed. Hampton v. State of Michigan, 377 N.W.2d 920 (Mich. App. 1985).
Shackling inmate thought to be suicidal may have been improper. Wells v. Franzen, 777 F.2d 1258 (7th Cir. 1985).
Intoxicated man hung himself inside cell. Holland v. Breen, 623 F.Supp. 284 (D.C. Mass. 1985).
CPR training qualifies one as expert on rescue attempts; no professional license required. Hake v. Manchester, Tp., 486 A.2d 836 (N.J. 1985).
Officials accused of not checking past jail records indicating suicidal tendencies. Partidge v. Two Unknown Police Officers, 751 F.2d 1448 (5th Cir. 1985).
Jailers hearing suicide threats not grounds for liability. Estate of Cartwright v. City of Concord, Cal., 618 F.Supp. 722 (D.C. Cal. 1985).
Jury to decide deputies' negligence in jail suicide following family's warnings. Hemly v. Bebber, 335 S.E.2d 182 (N.C. App. 1985).
Real cause of suicide is that detainee no longer wished to live, not any negligence on the part of officials; unusual dress not reason to suspect suicide. Horne v. Beason, 331 S.E.2d 342 (S.C. 1985).
Failure to admit medical review commission's report grounds for new trial; arrestee hung himself with socks. Dozlowski v. City of Amsterdam, 488 N.Y.S.2d 862 (A.D. 3 Dept. 1985).
Acts or omissions could hold city liable for suicide; officers accused of beating mentally ill arrestee. Madden v. City of Meriden, 602 F.Supp. 1160 (D. Conn. 1985).
Intoxicated arrestee's suicide blamed on inadequate jail design and supervision. Lightbody v. Town of Hampton, 618 F.Supp. 6 (D.C. N.H. 1984).
Detroit settles for $275,000 for suicide of arrestee who was initially stopped for no apparent reason. Martin v. City of Detroit, Detroit Free Press, 1/22/85.
Refusal to listen to boys screams could result in liability for his suicide. Brewer v. Perrin, 349 N.W.2d 198 (Mich. App. 1984).
Officials could be liable for inmate suicide with shoestring. Guglielmoni v. Alexander, 583 F.Supp. 512 (E.D. Pa. 1984).
Mental inability to bring suit tolls statute of limitations. Smith by and Through Smith v. City of Reno, 580 F.Supp. 591 (D. Nev. 1984).
Failure to take extra precautions for intoxicated prisoner could result in liability for suicide. Kanayurak v. Northslope Borough, 677 P.2d 893 (Alaska 1984).
Use of dog during arrest may constitute excessive force resulting in officers and city being liable; city and county may be liable for arrestee's suicide attempt resulting from poor county jail conditions. Soto v. City of Sacramento, 567 F.Supp. 662 (E.D. Cal. 1983).
No liability for officer's failure to handcuff arrestee who shot himself when helping them search house for stolen items. Langford v. City of Leesville, 442 So.2d 1375 (La. App. 1983).
No liability for jail suicide; no right for inmate to make telephone call to lawyer. State Bank of St. Charles v. Camic, 712 F.2d 1140 (7th Cir. 1983). No liability to police chief for arrestee's suicide. Young v. City of Ann Arbor, 336 N.W.2d 24 (Mich. App. 1983).
No liability for jail suicide committed with belt. Dezort v. Village of Hinsdale, 441 N.E.2d 367 (Ill. App. 1982).
Recovery under Section 1983 on theory of negligence denied to parent of suicide victim. Meshkov v. Abington Township, 517 F.Supp. 1280 (E.D. Pa. 1981).
Florida sheriff who violated administrative rule held liable for inmate's suicide. Robert v. Stokley, 388 So.2d 1267 (Fla. App. 1980).
Florida Appellate Court rules that sheriff's office was not liable for suicide of an inmate who hung himself with his belt. Guice v. Enfinger, 389 So.2d 270 (Fla. 1980).
Michigan court dismisses Section 1983 suit by relatives of prisoner who hung himself while incarcerated in city jail. Moomey v. City of Holland, 490 F.Supp. 188 (1980).
Inmate's suicide attempt is not contributory negligence; state corrections manual is inadmissible on issue of county jail official's duty to inmate. Cole v. Multnomah Co., 592 P.2d 221 (Ore. App. 1979).
Court orders new trial in civil rights suit due to possible altering of cell check log after inmate committed suicide. Swietlowich v. Co. of Buck, 610 F.2d 1157 (3rd Cir. 1979).
Court orders retrial in action brought for attempted suicide of youth at correctional facility; state not liable in money damages for constitutional violations. Figueroa v. State, 604 P.2d 1198 (Hawaii, 1978).
Jail officials entitled to instruction on decedent's contributory negligence and on intervening causation in wrongful death suit. Harrell v. City of Belen, 603 P.2d 722 (N.M. 1979).
Supreme Court holds that a law enforcement agency cannot avoid liability for a suicide by placing a prisoner in a county jail, under a contractual arrangement. Logue v. U.S., #72-656, 412 U.S. 521 (1973). [N/R]