A.H. v. St. Louis County, Missouri, No. 17-1198 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's grant of summary judgment dismissing plaintiffs' Fourteenth Amendment and wrongful death claims, as well as plaintiffs' claims under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, et seq., and the Rehabilitation Act (RA), 29 U.S.C. 701, et seq. Plaintiffs filed suit after Jereme Hartwig committed suicide by hanging himself with a bed sheet in his cell when he was confined at the St. Louis County Justice Center. The court held that plaintiffs failed to show that any defendant was deliberately indifferent to a substantial risk that Hartwig would commit suicide; the clinical psychologist's professional judgment, even if negligent, fell well short of deliberate indifference; the corrections officer's failure to recall the details of her monitoring at a deposition three years later did not create a genuine issue that she failed to conduct the hourly monitoring of inmates under the jail's suicide prevention policy; in regard to the Missouri wrongful death claim, the jailer performed her duties in accordance with the suicide prevention policy and did not breach a ministerial duty; and the ADA and Rehabilitation Act claims failed to state a claim.
Court Description: Loken, Author, with Beam and Kelly, Circuit Judges] Civil case - Civil rights. In action alleging defendants violated plaintiffs' decedent's civil rights by failing to protect him from a known risk of harm - death by suicide while detained at the County jail - the district court did not err in granting defendants summary judgment because plaintiffs failed to show that any defendant was deliberately indifferent to a substantial risk that their decedent would commit suicide; a clinical psychologist's exercise of professional judgment in assessing the man's risk of suicide, even if negligent, fell well short of deliberate indifference; other evidence established a defendant jailer had conducted hourly checks as required by the jail's suicide prevention policy; with respect to plaintiffs' Missouri wrongful death claim, the jailer performed her duties in accordance with the suicide prevention policy and did not breach a ministerial duty; plaintiffs' ADA and Rehabilitation Act allegations failed to state a claim as they essentially state claims of inadequate medical treatment which this court has previously held cannot be brought under either of the acts.
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