Penn v. Escorsio, No. 13-2309 (1st Cir. 2014)Annotate this Case
Defendants worked as corrections officers at a jail where Matthew Lalli was being held as a pre-trial detainee. Defendants were involved in a series of troubling events that led to Lalli’s attempted, and almost completed, suicide. Plaintiff, Lalli’s guardian, sued Defendants, claiming deliberate indifference in violation of Lalli’s Fourteenth Amendment rights. Defendants filed a motion for summary judgment, asserting that they were not deliberately indifferent and were entitled to qualified immunity. The district court denied the motion, determining that a reasonable jury could find Defendants acted with deliberate indifference toward Lalli and that Defendants were not entitled to qualified immunity on the claim of deliberate indifference at the summary judgment stage. The First Circuit affirmed, holding that Defendants could not show they were entitled to qualified immunity at the summary judgment phase of this litigation.