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Seven prison officers who had been accused of showing deliberate indifference to an inmate's suicide are protected by qualified immunity, the Eleventh Circuit ruled on Wednesday. After Darius James killed himself while awaiting trial, his mother sued the officers, alleging that they knew of James' suicide risk and did nothing.
James' mother had failed to show that individual officers had a subjective knowledge of the risk of suicide, the Eleventh Circuit found. While there was circumstantial evidence that prison officials generally may have been aware of James' suicide risk and may have mishandled his care, there was not enough evidence specific to the officers to counteract their qualified immunity.
In and out of Suicide Watch
When James was initially arrested for robbery and home invasion, he was screened by a nurse, who warned of a high risk of suicide, saying James felt "ready to die." He spent the night in the prison's suicide prevention wing, and the next day claimed he was not suicidal, though he demonstrated obvious mental and behavior issues. He was removed from suicide watch. Over the next few weeks, he repeatedly was put on and removed from the watch.
After months in jail, in which James was often assaulted by other prisoners and occasionally complained of stress and difficulty sleeping, he committed suicide. His mother filed a 1983 complaint against the county sheriff and ten correctional officers, alleging that their deliberate indifference to James' suffering resulted in his suicide. On summary judgment, the district court found that seven of the officers were not entitled to qualified immunity.
Individual, Subjective Knowledge Necessary
In a suicide case, a prison official will have violated a prisoners right if they show deliberate indifference to his suicide. Deliberate indifference requires subjective knowledge of a risk of serious harm and more-than-negligent disregard of that risk. Without knowledge that a prisoner is suicidal, a failure to prevent the suicide cannot constitute deliberate indifference.
Which is just what the seven officers argued on appeal -- that they had no actual knowledge that James was suicidal, nor any reason to believe he was. Though each officer had some knowledge of James' mental health and behavioral problems, none were aware of a strong risk of suicide, the Eleventh Circuit found. While some officers had removed James to the suicide prevention wing in the past, significant time had elapsed between those events and James' actual suicide attempt.
Circumstantial evidence, such as an inmate's statement that officers generally were aware James was suicidal, was too weak to show that individual officers had knowledge of James' condition. Deliberate indifference must be shown for each officer individually -- it cannot be ascribed to the prison generally.