After Anthony Ybarra attempted suicide by hanging, bystanders tried to provide emergency aid. Ybarra’s estate alleged that Deputy Gregory Spicher stopped the bystanders from performing CPR, causing a violation of substantive due process. The district court denied Spicher qualified immunity. The Eleventh Circuit held that the district court applied the wrong culpability standard. In this setting, deliberate indifference or recklessness alone was not enough; the estate had to show that Spicher acted with a purpose to cause harm to Ybarra. Because the district court had not evaluated the evidence under that standard or determined whether the parties needed to develop the record further, the Eleventh Circuit vacated the judgment and remanded for reconsideration. The court did not decide whether a jury could ultimately find the required purpose.