Gray v. City of Detroit.

U.S. Appeals Court

SUICIDE

MEDICAL CARE

SUPERVISION

Gray v. City of Detroit, 399 F.3d 612 (6th Cir. 2005). The personal representative of the estate of a pretrial detainee who had committed suicide while in a police cell at a hospital brought a [section] 1983 action alleging inadequate medical treatment and failure to adequately monitor the detainee. The district court granted summary judgment for the defendants and the personal representative appealed. The appeals court affirmed. The court held that the city could not be held liable for deliberate indifference given the absence of an obvious and clear suicide risk. The court concluded that an officer enjoyed qualified immunity because the detainee's pre-suicide behavior did not give rise to a duty to monitor for suicide. The detainee had registered only physical complaints and had engaged in no self-injurious behavior at the hospital. The officer was not aware of, and could not be charged with knowledge of the detainee's behavior prior to reaching the hospital, according to the court. The court found that the city could not be held liable for failure to adequately train its officers regarding suicides, where officers complied with city policies regarding medical care, including screening by an intake nurse at the hospital, and no previous inmate suicides had occurred in the hospital cells. Although the detainee had been destructive before he was transferred to the hospital--ripping a phone from his cell wall and breaking a sink and toilet--the court noted that none of his destructive acts had been self-directed. (Detroit Receiving Hospital, Michigan)