Adams v. Ferguson, No. 17-1484 (4th Cir. 2018)Annotate this Case
Plaintiff, the personal representative of Jamycheal Mitchell, filed suit against defendant and 49 others, alleging claims under 42 U.S.C. 1983 and state law. Jamycheal died from severe malnutrition in Regional Jail while awaiting a bed in the Hospital. Defendant was the Commissioner of the Virginia Department of Behavioral Health & Developmental Services, the agency responsible for overseeing state mental health hospitals. The Fourth Circuit held that it lacked jurisdiction to review the district court's denial of defendant's motion to dismiss the state law claims and remanded those claims to the district court. The court also held that Eleventh Amendment absolute immunity did not bar the suit where defendant was being sued in her personal capacity and plaintiff sought to recover only from defendant, not the Commonwealth of Virginia. Finally, the court held that defendant was entitled to qualified immunity from suit on the section 1983 claims where no clearly established law dictated that housing mentally ill inmates in prisons, rather than transferring them to state mental health facilities, automatically and alone amounted to an objectively excessive risk to inmate health and safety.