Shelton v. AR Dept. of Human Services, et al., No. 11-1822 (8th Cir. 2012)
Annotate this CasePlaintiff, as the administratrix of Brenda Shelton's estate, appealed the district court's dismissal of her civil action against several public officials and health officials. The complaint alleged shortcomings in the way medical professionals at a state mental health facility responded after Brenda hanged herself while a patient at the facility. The district court dismissed all federal claims with prejudice and dismissed the state law claims without prejudice, electing not to exercise jurisdiction over the state law claims. The court held that the circumstances did not trigger duties related to involuntary commitment nor did they give rise to a constitutional-level of care. The court also held that a claim based upon an improper medical treatment decision could not be brought pursuant to either the Americans with Disabilities Act, 42 U.S.C. 12101 et seq., or the Rehabilitation Act, 29 U.S.C. 701 et seq.
Court Description: Civil case - Civil Rights. In action alleging defendants failed to meet their duty of care to plaintiff's decedent who committed suicide while voluntarily hospitalized at the Arkansas State Hospital, the defendants did not owe a constitutional-level duty of duty of care to the deceased patient; a claim based on an allegedly improper medical treatment decision cannot be brought pursuant to either the Americans with Disabilities Act or the Rehabilitation Act.
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