Perry v. Adams, No. 19-2478 (8th Cir. 2021)
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The Eighth Circuit reversed the district court's denial of defendant's motion for summary judgment in an action brought by DeJuan Bison's family after DeJuan committed suicide by hanging himself in a cell after being transferred from the St. Louis City Justice Center to the City of Jennings Detention Center. Plaintiffs alleged that defendant was an officer who failed to notify detainee intake personnel with the City that Brison was suicidal when St. Louis transferred Brison into the City's custody.
The court concluded that defendant did not violate any clearly established right where she was not required to second-guess a mental health professional's judgment as to the substantiality of a suicide risk. The court explained that a mental health professional had determined that DeJuan was not suicidal and his classification as under Close Observation was, in an of itself, indicative of the absence of suicide risk.
Court Description: [Melloy, Author, with Smith, Chief Judge, and Loken, Circuit Judge] Civil case - Civil rights. In action alleging the defendants were deliberately indifferent to a detainee's suicide risk, plaintiff alleged defendant Adams, a St. Louis city jail officer, failed to notify detainee intake personnel with the City of Jennings that the detainee was suicidal when St. Louis transferred the detainee to the Jennings jail; the district court denied Adams's motion for summary judgment based on qualified immunity, and Adams appeals. Held, Adams was entitled to summary judgment. Here, a mental health professional had determined that the detainee was not suicidal and his classification as under Close Observation was, in an of itself, indicative of the absence of suicide risk. As a result, Adams did not violate any clearly established right as she was not required to second-guess a mental health professional's judgment as to the substantiality of a suicide risk.
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