Sanchez v. Oliver, No. 20-50282 (5th Cir. 2021)Annotate this Case
After Eli Gauna, Jr. committed suicide while being held in the Bell County jail as a pretrial detainee, his mother filed suit against the licensed clinical social worker who was the mental health professional that evaluated Gauna and took him off suicide watch. The district court granted summary judgment for the social worker, concluding that she was entitled to qualified immunity and had not acted with deliberate indifference to Gauna's serious medical needs.
The Fifth Circuit reversed, concluding that the social worker, as an employee of a private organization systematically organized to perform a major administrative task, is not entitled to qualified immunity. Furthermore, plaintiff provided sufficient evidence regarding whether the social worker knew about Gauna's suicide risk to raise a genuine dispute of material fact over whether the social worker was deliberately indifferent to Gauna's medical needs. In this case, the social worker knew of Gauna's suicidal ideations and chose to have him taken off suicide watch, placing him into the general population where he would have access to tie-off points and ligatures, including the bedsheets with which he eventually hanged himself. Accordingly, the court remanded for further proceedings.