Coleman Ex Rel. Coleman v. Parkman.

U.S. Appeals Court

PRISONER SUICIDE

Coleman Ex Rel. Coleman v. Parkman, 349 F.3d 534 (8th Cir. 2003). The administratix of a pretrial detainee's estate brought an action, alleging that prison officials had been deliberately indifferent to the risk that the detainee would commit suicide. The district court granted summary judgment for the defendants in part, and the parties appealed. The appeals court affirmed in part and dismissed in part. The appeals court held that summary judgment was precluded by genuine issues of material fact as to whether the arresting officer knew that the detainee presented a substantial suicide risk, and whether a jailer recklessly failed to take reasonable measures. The arresting officer had been told by someone who was with the detainee before his arrest, that the detainee had been carrying a rifle and threatening suicide. After interviewing the detainee, the officer concluded he was not a suicide risk. Jail records stated that the detainee had threatened suicide and needed to be placed in isolation and monitored. The detainee was placed in the jail's drunk tank, instead of the holding cell that was usually used for suicidal inmates. The drunk tank had eighteen exposed bars, while the holding cell had none. The drunk tank was difficult to observe because it was upstairs in the jail, unlike the holding tank. Because the detainee was assigned to the drunk tank, and in spite of his being on a suicide watch, an officer issued the detainee the usual items, including a bed sheet. The officer checked on the detainee at 1:30 a.m.; the detainee was found hanging from the exposed bars by a bed sheet at 1:42 a.m. (St. Francis County Jail, Arkansas)