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Vivian Jacksonv.Preston West, et al.

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.14-13282
DecidedJune 3, 2015
Reporter787 F.3d 1345
JudgesEleventh Circuit Judges Beverly B. Martin and Robin S. Rosenbaum, and District Judge L. Scott Coogler, sitting by designation; Martin authored the opinion
Tags
CivilCivil RightsFourteenth AmendmentSection 1983Qualified ImmunitySummary JudgmentReversalRemand
Case Summary

Vivian Jackson, acting for the estate of her 22-year-old son Darius James, sued seven Marion County Jail officers under 42 U.S.C. § 1983 after James died by suicide in pretrial detention. James had earlier expressed suicidal thoughts, received suicide precautions, reported stress and anxiety, and experienced several behavioral incidents, but the record did not identify what each defendant knew before his death. The district court denied the officers’ renewed motions for summary judgment, reasoning that an inmate declaration, housing assignments, and expert opinions could support deliberate-indifference findings. The Eleventh Circuit reversed. It held that a pretrial detainee’s due-process protection from self-inflicted injury uses the deliberate-indifference standard, which requires each officer’s subjective knowledge of a strong suicide risk, disregard of that risk, and conduct beyond negligence. The cited evidence was too vague or nonspecific to connect that knowledge to any defendant; the officers’ responses to James’s explicit July suicide threat also followed protocol. The court declined to consider a separate claim based on the alleged delay in responding to the hanging because it had not been pleaded. It remanded with instructions to grant summary judgment to all seven officers.

Opinion

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