Leftwich v. County of Dakota, No. 20-1821 (8th Cir. 2021)
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After Cameron Leftwich committed suicide in jail, his father filed suit alleging 42 U.S.C. 1983 claims against defendants for failure to provide adequate medical care and failure to train, as well as wrongful death claims under Minnesota law.
The Eighth Circuit affirmed the district court's grant of summary judgment for defendants, concluding that plaintiff failed to show that any of the individual defendants (or any other relevant official) was deliberately indifferent to and subjectively aware of the risk of suicide. Therefore, there was no underlying constitutional violation and the individual defendants, as well as the city and the county, are entitled to summary judgment on the section 1983 claims. The court also concluded that the district court did not err in determining Defendants Wegner and Swanson had public official immunity for plaintiff's Minnesota wrongful death claims because they were performing discretionary duties. Furthermore, the county is entitled to vicarious official immunity. The court further concluded that the county is entitled to public entity or statutory immunity because the county's decision to have a mental health exam performed within 72 hours of incarceration is a policy making and not an operational government decision. Finally, the court concluded that the district court did not abuse its substantial discretion by denying plaintiff's motions to amend the scheduling order and file an amended complaint after the deadlines had passed.
Court Description: [Loken, Author, with Colloton and Benton, Circuit Judges] Civil case - Civil rights. In this case where plaintiff's decedent committed suicide while detained at the Dakota County Jail, the individually-named defendants did not have actual knowledge of a risk of suicide and were not deliberately indifferent to such a risk; as a result, there was no constitutional violation, and the individual defendants, as well as the City and County, were entitled to summary judgment on the Section 1983 claims; the district court did not err in determining defendants Wegner and Swanson had public official immunity for plaintiff's Minnesota wrongful death claims as they were performing discretionary duties; the County was, as a result, entitled to vicarious official immunity; the County is entitled to public entity or statutory immunity because the County's decision to have a mental health exam performed within 72 rather than 24 hours of incarceration is a policy making and not an operational government decision; the district court did not abuse its substantial discretion by denying plaintiff's motions to amend the scheduling order and file an amended complaint after the deadlines had passed.
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