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Gabrielle Hillv.Theodore Jackson et al.

CourtCourt of Appeals of Georgia
Docket No.A15A1778
DecidedMarch 24, 2016
JudgesCourt of Appeals of Georgia
Tags
CivilTort LawWrongful DeathGovernment LawQualified ImmunitySection 1983Summary JudgmentReversal
Case Summary

Gabrielle Hill brought a wrongful-death action after her father died by suicide while confined in the Fulton County jail. She sued county officials, jail personnel, and medical contractors, alleging failures in supervision, protection, and medical care. The trial court granted summary judgment to all defendants involved in the appeal. The Court of Appeals affirmed judgment for most defendants but reversed as to two jail employees. Applying the distinction between ministerial and discretionary duties, the court concluded that the record could support a triable issue about whether those employees failed to perform ministerial responsibilities concerning jail records and suicide-risk information. The court otherwise found no evidence creating a genuine issue on the elements of the claims against the sheriff, other officials, or the medical defendants, including evidence that the medical contractor knew the decedent was present on the relevant date. The court therefore affirmed in part and reversed in part, allowing the claims against the two employees to proceed while leaving the remaining summary judgments intact. The panel concurred.

Opinion

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Gabrielle Hill v. Theodore Jackson et al. — The Atlanta Gleaner