Luckert v. Dodge County, No. 11-1178 (8th Cir. 2012)
Annotate this CaseTroy Sampson committed suicide while detained at the Dodge County Jail (DCJ) in Nebraska. Sampson's mother, Sherry Luckert, acting as the personal representative of Sampson's estate, sued Dodge County and jail officials under 42 U.S.C. 1983, claiming they were deliberately indifferent to Sampson's medical needs, thus violating his due process rights. A jury found Dodge County and DCJ's director and nurse (collectively, Appellants) liable and awarded Luckert actual and punitive damages. The district court denied Appellants' motion for judgment as a matter of law, entered judgment in favor of Luckert, and awarded Luckert attorney fees and costs. The Eighth Circuit Court of Appeals reversed the denial of judgment as a matter of law and vacated the awards of damages and attorney fees and costs for Luckert, holding that all Appellants were entitled to judgment as a matter of law, and therefore, it was unnecessary to address their remaining claims.
Court Description: Civil case - civil rights. Defendants were entitled to judgment as a matter of law on plaintiff's claim that they were deliberately indifferent to her decedent's medical needs as both defendant Julian and defendant Campbell were entitled to qualified immunity; while defendant Julian may have been negligent in certain actions she took, such as downgrading the deceased from a twenty-minute to a thirty-minute suicide watch, her actions did not constitute deliberate indifference when viewed in the context of the affirmative, deliberate steps she took to prevent his suicide while he was incarcerated at the Dodge County Jail; under defendant Campbell's management of the jail, it had it in place a practice where inmates at risk of committing suicide were identified, put on suicide watch, given medical attention by a registered nurse and, if necessary, a contract psychologist; as a result, defendant Campbell was entitled to qualified immunity; Dodge County was also entitled to judgment as a matter of law as none of the alleged deficiencies in its procedures and practices demonstrated that the County had a custom, policy or practice violating the deceased's constitutional rights and causing his suicide. Judge Bye, dissenting.
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