Prison officials have civil-suit immunity in prison suicide case, SCOTUS rules
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Qualified immunity shields Delaware prison officials sued for failing to prevent the suicide of an arrestee with mental health problems, the U.S. Supreme Court has ruled in a per curiam decision.
The court granted cert and ruled (PDF) that there was no violation of clearly established law in the case of Christopher Barkes, who was arrested in November 2004 for a probation violation. As a result, the officials were entitled to qualified immunity.
After his arrest, Barkes was taken to the Howard R. Young Correctional Institution in Wilmington, where a nurse conducted a mental health screening. Barkes disclosed a previous suicide attempt in 2003 and his history of psychiatric treatment. But he said he was not thinking about killing himself. Finding few risk factors for suicide, the nurse did not initiate any special suicide prevention precautions.
Barkes told his wife in a phone call that evening that he planned to kill himself, but she did not tell anyone at the prison about the call, the opinion says. Barkes hanged himself the next day. The suit by Barkes’ wife and children alleged violation of his right to be free of cruel and unusual punishment.
The Supreme Court’s per curiam opinion overturns a decision by the Philadelphia-based 3rd U.S. Circuit Court of Appeals, which cited its own precedent in finding a clearly established right to adequate suicide-prevention measures.
The Supreme Court cited disagreement among appeals courts and said the 3rd Circuit precedent didn’t clearly establish such a right. Nor did any opinion of the U.S. Supreme Court, the per curiam opinion said. “No decision of this court even discusses suicide screening or prevention protocols,” the Supreme Court said.
The case is Taylor v. Barkes.
