Mental problems (Prisoner).

30. Mental Problems (Prisoner)

U.S. District Court   Bozeman v. Orum, 199 F.Supp.2d 1216 (M.D.Ala.
                      2002). The representative of the estate of a
  DELIBERATE          pretrial detainee brought a [section] 1983 action
  INDIFFERENCE        against a sheriff and officials at a county
                      detention facility, alleging that the detainee's
  FAILURE TO          death was the result constitutional violations.
  PROVIDE CARE        The district court held that detention officers'
                      use of force to restrain the detainee did not
  PRETRIAL            violate his Fourteenth Amendment right against
  DETENTION           the use of excessive force, even though the
                      officers threatened to "kick" the detainee's
                      "ass." The officers apparently punched or slapped
                      the detainee, and the detainee died as the result
                      of the officers' actions, but the court found
                      that some level of force was necessary to restore
                      order where the detainee was apparently
                      undergoing a mental breakdown in his cell.

                      The court held that nurses at the detention
                      facility were not deliberately indifferent to the
                      serious medical needs of the detainee when they
                      failed to obtain treatment and medication upon
                      learning that the detainee had been evaluated for
                      mental health problems and prescribed medication
                      in the past. The court noted that the nurses had
                      no knowledge during intake beyond a "slight flag"
                      of past evaluations for mental illness and that
                      the detainee had medication to help him "rest."
                      The court also found that the failure of the
                      detention facility to implement a policy
                      requiring staff to follow up on inmates who had
                      acknowledged past mental health problems or
                      evaluations for mental health problems, did not
                      violate the detainee's Fourteenth Amendment right
                      to adequate medical care. The court held that
                      municipal jails are not required to provide
                      on-site psychiatric care for their inmates, and
                      that the detention facility was not required to
                      train its officers in diagnosing or treating
                      mental illness. (Montgomery County Detention
                      Facility, Alabama)

U.S. Appeals Court    Hallett v. Morgan, 296 F.3d 732 (9th Cir. 2002).
                      A class of prisoner's at a women's state prison
  FAILURE TO          who brought a [section] 1983 action against
  PROVIDE CARE        prison officials moved to extend jurisdiction
                      over a consent decree for an additional period of
                      time, to have prison officials held in contempt,
                      and to compel discovery. The district court
                      denied the motions and granted the prison
                      officials' motion to terminate the consent
                      decree. The appeals court affirmed in part,
                      reversed in part, and remanded. The appeals court
                      found that dental care and mental health
                      conditions at the prison did not violate the
                      Eighth Amendment. The appeals court found that
                      officials' substantial compliance with the
                      consent decree judgment was an acceptable defense
                      to the prisoners' motion to hold the officials in
                      civil contempt for past violations of the decree.
                      The court remanded the case for reconsideration
                      of allegations that the officials failed to
                      comply with consent decree requirements regarding
                      medical care. (Washington Corrections Center for
                      Women)

U.S. District Court   Pelletier v. Magnusson, 195 F.Supp.2d 214 (D.Me.
                      2002). A personal representative for the estate
  SUICIDE             of an inmate filed a [section] 1983 action,
                      alleging that state employees violated the Eighth
  FAILURE TO          Amendment by failing to prevent the inmate from
  PROVIDE CARE        committing suicide. The appeals court denied the
                      defendants' motion for summary judgment, in part.
                      The court found that summary judgment was
                      precluded by a genuine issue of material fact as
                      to whether correctional officers were aware of
                      clinical meeting notes that indicated that the
                      inmate was very anxious and was hearing voices,
                      and whether they were aware through logs and
                      verbal communication with officers, that the
                      inmate had earlier instances of decompensation.
                      The court also found that summary judgment was
                      precluded because of the spoilation of missing or
                      tampered documents relating to the inmate's
                      medical treatment, and whether a clinical social
                      worker refused to act on a medical
                      recommendation that the inmate required a
                      psychiatric evaluation. (Maine State Prison)