Smith-Dandridge v. Geanolous, No. 21-2459 (8th Cir. 2024)
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The case involves the death of Andrew Dawson Bell, who committed suicide while detained at the Washington County Detention Center (WCDC) in Fayetteville, Arkansas. Bell's mother, Judy Lynn Smith-Dandridge, filed a lawsuit against several Fayetteville Police Department officers, WCDC employees, nurses, and Washington County itself, alleging that they were deliberately indifferent to Bell's serious medical needs, in violation of 42 U.S.C. § 1983 and the Arkansas Civil Rights Act, Arkansas Code Ann. § 16-123-105. The district court granted summary judgment in favor of all defendants, and Smith-Dandridge appealed to the United States Court of Appeals for the Eighth Circuit.
Bell had a history of mental illness and substance abuse. On the day he died, Bell had called the police several times, reporting hallucinations of people trying to break into his apartment. Officers responded but found no evidence of a break-in. They arrested Bell for terroristic threats, disorderly conduct, and carrying a weapon. When Bell was processed into WCDC, he informed the intake officers of his mental health history, including a history of suicidal ideation. Despite this, he was placed in the general population.
The main issue on appeal was whether the police officers and WCDC personnel had knowledge of Bell's substantial risk of suicide and deliberately disregarded it. Smith-Dandridge argued that the officers’ interactions with Bell and their review of his arrest history established they had the requisite knowledge to establish deliberate indifference. However, the court found that while Bell's behavior put the officers on notice of signs of mental illness, it did not make it obvious to them that Bell had a substantial risk of suicide. Similarly, the court found that the WCDC personnel's inaction to prevent Bell's suicide did not constitute criminal recklessness.
The court also dismissed Smith-Dandridge's claim that Washington County was deliberately indifferent in its failure to train jail staff. The court found that Smith-Dandridge failed to show that the alleged deficient training caused WCDC personnel to be deliberately indifferent to Bell's substantial risk of suicide. As such, the court affirmed the district court's grant of summary judgment in favor of all defendants.
Court Description: [Kelly, Author, with Shepherd and Stras, Circuit Judges] Civil case - Civil rights. Plaintiff's decedent committed suicide by hanging while in custody at the Washington County Detention Center in Fayetteville, and plaintiff sued various officers of the Fayetteville police, employees and medical staff at the jail, and the County under Section 1983. The district court granted summary judgment for all defendants, and plaintiff appeals. Held: (1) the decedent's behavior before and at the time of his arrest put the Fayetteville police officer defendants on notice of signs of mental illness, but the evidence was not sufficient for a reasonable jury to find that the officers knew he was at a substantial risk of suicide and that they deliberately disregarded it; (2) the intake staff at the jail and the medical defendants' inaction to prevent the decedent's suicide did not constitute criminal recklessness or a violation of his constitutional rights; and (3) plaintiff's failure-to-train claims against the County fall with the individual claims against the jail staff and medical defendants.
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