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Psychiatric Quarterly

, Volume 60, Issue 1, pp 31–71 | Cite as

Custodial suicide: Evolving liability considerations

  • William D. O'Leary
Article

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Reference notes

  1. 1.
    National Study of Jail Suicides: Seven Years Later,Jail Suicide Update (Spring 1988).Google Scholar
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    Cohen, F. Legal Issues and the Mentally Disordered Inmate,1985 Source-book on the Mentally Disordered Prisoner 69.Google Scholar
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    Preventing Jail Suicides,On The Line (May 1988) John Howard Association Newsletter.Google Scholar
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    Training, Jail Suicide Update (Summer 1987).Google Scholar
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    See Prisoner Suicide- Caselaw and Standards, 30 Detention Reporter 3, at 6 (April 1986) in which the authors cite litigation as the prominent suicide prevention measure. “As the numbers of jail suicides increase, so too do the number of lawsuits. Ten years ago, it was unusual for a jail to be sued for negligence following a suicide. Today it is unusual if a suit is not filed.”Note that Section I(B) of this article details a similar increase in civil rights (42 USC 1983) suits.Google Scholar
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    See Overby v. Wille, 411 So.2d 1331 (1982), White v. Seekonk, 23 Mass.App.Ct. 139, 499 N.E.2d 842 (1986), Sudderth v. White, 621 S.W.2d 33 (Ky Cr App 1981), Kanayurak V. North Slope Borough, 677 P.2d 893 (Alaska, 1984), Strandell v. Jackson, 648 F.Supp. 126 (S.D.Ill. 1986), Partridge v. Two Unknown Police Officers, 751 F.2d 1448 (5th Cir. 1985), and Colburn v. Upper Darby Township, 838 F.2d 663 (3rd Cir. 1988).Google Scholar
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    See Prisoner Suicide-Caselaw & Standards,30 Detention Reporter 3, at 10 (April 1986).See also, Mass.Gen.L.ch40s.36B (1986) entitled “Cells; protective coverings, electronic audio systems and electronic security devices.”Google Scholar
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    Prosser writes: “the expert swimmer, with a boat and a rope at hand, who sees another drowning before his eyes, is not required to do anything at all about it, but may sit on the dock, smoke his cigarette, and watch the man drown.” SeeProsser & Keeton on Torts, 5th Ed, p.375 referring to Osterlind v. Hill, 263 Mass. 73, 160 N.E. 301 (1928).Google Scholar
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    Clinicians are only too aware of a duty to prevent harm as it relates to third parties as evidenced in Tarasoff v. Regents of University of California, 551 P.2d 345 (1976). In that case the court determined that when a patient bears a serious risk of physical harm to another, the therapist “bears a duty to exercise reasonable care to protect the foreseeable victim of the danger.”Google Scholar
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    The actual language of the statute is as follows: “every person who, under color of any statute, ordinance, regulation, custom or usage, of any State ... subjects or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity or other proper proceeding for redress.”Note that while mosts.1983 suits are filed in federal court relief can also be sought in state court.See, for example, Miga v. City of Holyoke, 398 Mass, 342, 497 N.E.2d 1 (1986).Google Scholar
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    429 U.S. 987 (1976).Google Scholar
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    See Bell v. Wolfish, 441 U.S. 520, 535 (1979). The 14th amendment proscribes against deprivation of life, liberty or property without due process of law.Google Scholar
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    551 F.2d 44, 47 (4th Cir. 1977).Google Scholar
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    56 U.S.L.W. 4664 (U.S. June 20, 1988).Google Scholar
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    Until 1978 the answer to this question was no. In Monroe v. Pape, 365 U.S. 167, 81 S.Ct. 473 (1961) the Supreme Court determined that municipalities were immune from liability under 42 U.S.C. 1983. Barrineau writes: “For 16 years following theMonroe decision the federal courts, including the U.S. Supreme Court, continued to grant absolute municipality immunity. Thus, although it was clear that law enforcement officers and other criminal justice practitioners were subject toSection 1983, it was also clear that a plaintiff usually would not be able to obtain sizeable damages simply because criminal justice practitioners do not earn a great deal of money.” H.E. Barrineau III,Civil Liability in Criminal Justice (1987) pp. 11–12.Google Scholar
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    436 U.S. 658 (1978).Google Scholar
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    See Molton v. City of Cleveland, 839 F.2d 240, 243 (6th Cir. 1988).Google Scholar
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    See Colburn v. Upper Darby Township, 838 F.2d 663, 671–673 (3rd Cir. 1988); Jackson v. City of Chicago, 646 F.Supp.. 926 (N.D.Ill., 1986).Google Scholar
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    107 S.C. 114 (2/25/87).Google Scholar
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    Id. at 1121.Google Scholar
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    See Litigation, Jail Suicide Update (Spring, 1987): “As with most litigation, the vast majority of jail suicide cases culminate in out-of-court settlements in sums ranging from $24,000 to $2.4 million.”Google Scholar
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    See Training,Jail Suicide Update (Spring, 1987) p.6 re “Garcia v. County of El Paso Consent Judgement.”Google Scholar
  27. 34.
    The cases which settled include Belen v. Harrell, 93 N.M. 601, 603 P.2d 711 (1979), White v. Seekonk, 23 Mass.App.Ct. 139, 499 N.E.2d 842 (1986), Sudderth v. White, 621 S.W.2d 33 (Ky.Ct.App. 1981), Kanayurak v. North Slope Borough, 677 P.2d 893 (Alaska 1984), and Jackson v. City of Chicago, 646 F.Supp.. 926 (N.D. Ill. 1986). With respect to two of the cases, lawyers did not disclose monetary terms of the settlement. Settlements in the other three cases included $30,000, $50,000 and $125,000. Plaintiffs attorneys recited the following types of facts as tending to strengthen their case: failure to remove the juvenile detainees clothes after he had made a suicide threat; failure to remove the detainees belt after he had had made a suicide threat; and failure to use video equipment. in at least one instance the detention facility instituted new procedures for prevention although such was not required by the settlement agreement.Google Scholar
  28. 35.
    Partridge v. Two Unknown Police Officers, 751 F.2d 1448 (5th cir. 1985).Google Scholar
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    Overby v. Wille, 411 So.2d 1331 (Fla. app. 1982); Figueroa v. Hawaii, 604 P.2d 711 (N.M. 1979).Google Scholar
  30. 37.
    Colburn v. Upper Darby Township, 838 F.2d 663 (3rd Cir. 1988); Strandell v. Jackson County, Ill.., (648 F.Supp. 126 (S.D.Ill. 1986).Google Scholar
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    In Miga v. City of Holyoke, 398 Mass.343 at 351, 497 N.E.2d 1 at 8 (Mass. 1986) the court stated that punitive damages were available where the defendant's conduct is “motivated by evil motive or intent, or where it involves reckless of callous indifference to the plaintiffs constitutional rights. The test employed in Falkenstein v. Bismark, 268 N.W.2d 787, 793 (N.D. 1978) test was less onerous; the court was willing to find liability where the defendant acted “willfully, or with malice, or with reckless disregard of the rights of the complaining party, or where he has not acted in good faith.”Google Scholar
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    398 Mass. 343, 497 N.E.2d 1 (1986). Miga involved the death by hanging of an intoxicated woman who had been placed in a cell in an unconscious state. The estate was awarded $133,260; including $13,260 for wrongful death and funeral expenses (originally the award was $22,100, which was offset by the defendants 40% contributory negligence) $20,000 in compensatory damages and $100,000 in punitive damages against two police defendants.Google Scholar
  33. 40.
    No. 86-3417 (6th Cir. June 15, 1987).Schajatovic involved the death of a 17 year old arrested for DUI, who obtained access to a police gun while he was in custody and shot himself. The jury awarded $655,000 for wrongful death and funeral expenses.Google Scholar
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    268 N.W.2d 787 (N.D. 1978).Falkenstein involved the suicide by hanging of a young man who had been arrested for DUI and was placed in “the hole” after “foulmouthing” an officer. $58,000 was awarded including $27,000 for wrongful death, as well as $25,000 in compensatory damages, and $6,000 in punitive damages against one custodial defendant.Google Scholar
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    839 F.2d 240 (7th Cir. 1988).Molton involved the death by hanging of an intoxicated detainee. The court upheld a $45,000 wrongful death award.Google Scholar
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    The court referred to the facts of the case as evidencing “reprehensible conduct shocking to the conscience and offensive to all standards of common decency which clearly rise to the threshold of callous disregard for the decedent's rights.” Miga 497 N.E.2d at 8.Google Scholar
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    For an instructive dissertation of the doctrine of qualified immunity see Robinson, C.D., Legal Rights Duties and Liabilities of Criminal Justice Personnel (1984).Google Scholar
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    56 U.S.L.W. 4664 (U.S. June 20, 1988).Google Scholar
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    Consider the evolution of a standard of care in Massachusetts. In Slaven v. Salem, 386 Mass. 885 at 887, 438 N.E.2d 348, 349 (1982) the court indicated that it had “never specifically addressed the issue of the duty, if any, owed by prison officials to a person within their custody and control.” The court did not recognize such a duty in that case because the plaintiffs failed to introduce evidence to meet the test outlined in the Restatement (of Torts 2d); namely, that the custodians knew or had reason to know of suicide risk. Nevertheless, Justice Liacos wrote for the court: “We assume without deciding, that the Restatement (of Torts 2d) would be followed in the Commonwealth.” Apparently, that assumption was enough for the Massachusetts Appeals Court, who in White v. Seekonk, 23 Mass. App. Ct. 139, 499 N.E.2d 842 (1986) referenced Slaven in holding that the question of whether officers knew or had reason to know that a detainee posed a suicide risk was a factual one precluding summary judgement. Similarly, in Miga v. City of Holyoke, 398 Mass. 343, 497 N.E.2d 1 (Mass 1986) the Massachusetts Supreme Judicial Court upheld a wrongful death judgement on behalf of the estate of a custodial suicide decedent.Google Scholar
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    838 F.2d 663 3rd Cir. 1988).Google Scholar
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    839 F.2d 240 (6th cir. 1988).Google Scholar
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    768 F.2d 303 (10th Cir. 1985).Google Scholar
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    677 P.2d 893 (Alaska, 1984).Google Scholar
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    Williams v. City of Lancaster, 639 F.Supp. 377, 384 (E.D. Pa. 1986).Google Scholar
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    Suicide in Massachusetts Lockups 1973–1984, Special Commission to Investigate Suicide in Municipal Detention Centers, (May 1984) at 3.Google Scholar
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    Thus, where an intoxicated detainee, who had suffered a series of traumatic family losses of which the custodians were aware, was placed in protective custody and isolation and subsequently hung herself the defense offered argument that the decedent “was confined in an environment that facilitated suicide;” and that circumstances which caused the morbid state of mind resulting in her impulsive suicide included confinement, isolation, and humiliation. Kanayurak v. North Slope Borough, 677 P.2d 893 (Alaska 1984).Google Scholar
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    268 N.W.2d 787 (N.D. 1978).Google Scholar
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    106 Ariz. 265, 471 P.2d 265 (1970).Google Scholar
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    Id. at 269.Google Scholar
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    See Thomas v. Williams, 120 Ga. App. 321, 124 S.E.2d 409 (1962), Shuff v. Zurich-American Insurance Co. 173 So.2d 392 (La. App. 1965), Barlow v. New Orleans, 257 La.91, 241 So.2d 501 (1970), Daniels v. Anderson, 195 Neb. 95, 237 N.W.2d 397 (1975), Falkenstein v. City of Bismark, 268 N.W. 2d 787 (ND 1978), Overby v. Willie, 411 So. 2d 1331 (1982).Google Scholar
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    Shuff, 173 So.2d 392 (La. App. 1965).Google Scholar
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    Thomas, 120 Ga. App. 321, 124 S.E.2d 409 (1962).Google Scholar
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    195 Neb. at 99, 237 N.W.2d at 401.Google Scholar
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    35 Ill.App.3d 703, 709; 342 N.E.,2d 468, 474 (Ill.App.Ct. 1976).Google Scholar
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    677 P.2d 893 (Alaska 1984).Google Scholar
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    Id. at 899.Google Scholar
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    621 S.W.2d 33 (Ky.Ct.App. 1981).Google Scholar
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    398 Mass. 343, 497 N.E.2d 1 (Mass. 1986).Google Scholar
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    778 F.2d 678 (11th Cir. 1985).Google Scholar
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    768 F.2d 303 (10th Cir. 1985).Google Scholar
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    See Overby v. Willie, 411 So.2d 1331 (Fla. App. 1982) in which the court reversed a summary judgement citing facts indicating the decedents mental illness. The decedent had flagged down a cruiser stating that he thought he had hurt someone and requesting transport to a mental health center. Further, the desk sargeant had classified the decedent in his record as a “probable” Signal 20 which meant that he was mentally incompetent.See also Falkenstein v. City of Bismark, 268 N.W.2d 787 (N.D. 1978) in which the court stated that the fact that the decedent had no previous history of mental illness gave credence to the plaintiffs argument that the conditions of confinement were so atrocious as to compel a sane person to commit suicide.Google Scholar
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    See generally J. Haycock, this edition.Google Scholar
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    109 Ill.App.3d 976, 441 N.E.2d 367 (Ill. App. Crt. 1982).Google Scholar
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    Id. at 981, 441 N.E.2d at 372.Google Scholar
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    Id. at 982, 441 N.E.2d at 373 (Lindberg J. dissenting).Google Scholar
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    See Miga v. City of Holyoke, 398 Mass. 342, 497 N.E.2d 1 (Mass 1986), in which the court upheld a finding ofs. 1983 liability. In so doing it noted the police departments' knowledge of the decedents history of mental illness and attempted suicide.Google Scholar
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    677 P.2d 893 (Alaska 1984).Google Scholar
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    838 F.2d 663 (3rd Cir. 1988).Google Scholar
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    See D.B. v. Tewksbury, 545 F.Supp. 896 (D.Or. 1982) which compelled the removal of children from adult facilities.See also, Belen v. Harrell, 603 P.2d 711 (N.M. 1979) which focused upon negligence of custodial officials regarding the suicide by hanging of a juvenile housed in an adult lock-up who had expressed suicide intent. The case was settled out of court.Google Scholar
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    Community Research Forum, Juvenile Suicides in Adult Jails—Findings from a National Survey of Juveniles in Secure Detention Facilities (University of Illinois, 1983).Google Scholar
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    See generally, D. Steinhart & B. Krisberg, Children in Jail,State Legislatures, March 1987 at 12–16.Google Scholar
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    42 USC s. 5601et seq. (“JJDPA”).Google Scholar
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    See Survey Documents 401 Suicides in Jails and Lockups in 1986, 19Criminal Justice Newsletter 1 (June 1, 1988).Google Scholar
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    But see Schajatovic v. City of Mayfield, No. 86-3417 (6th cir. 6/15/87) in which an officer indicated that he had been trained concerning a suicide profile but that he did not believe the defendant was a risk. Although the defendant was intoxicated there was no history of suicidal ideation. The court found liability in negligence, not on the question of failure to identify a suicide risk, but because the police violated a gun regulation, whereby the decedent obtained access to a gun and shot himself.Google Scholar
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    23 Mass.App.Ct. 139, 499 N.E.2d 842 (Mass. App. Ct. 1986).Google Scholar
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    On May 1, 1984 the Special Commission to Investigate Suicide in Municipal Detention Centers submitted to the legislature its final report entitled “Suicides in Massachusetts Lock-ups 1973–1984.” Most of the Commission's recommendations regarding surveillance and construction were subsequently codified in Mass.Gen.L.c. 40,s. 36B.Google Scholar
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    Id. at 140, 499 N.E.2d at 844.Google Scholar
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    Survey Documents 401 Suicides in Jails and Lockups in 1986, supra, note 80, at 2Google Scholar
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    Cohen, F., Legal Issues and the Mentally Disordered Inmate,1985 Sourcebook on the Mentally Disordered Prisoner 69.Google Scholar
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    See Standards Manual of the Law Enforcement Agency Accreditation Program, (1983) Commission on Accreditation for Law Enforcement Agencies, Inc. (hereinafter CALEA); Standards for Adult Local Detention Facilities, Second Edition (1981) American Correctional Association and Commission on Accreditation for Corrections (hereinafter ACA/CAC); and, Standards for Health Services in Jails, (1987), National Commission on Correctional Health Care (hereinafter NCCHC).Google Scholar
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    See Prisoner Suicide-Caselaw and Standards, 30Detention Reporter 3 (April 1986).Google Scholar
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    648 F.Supp..126 (S.D.Ill. 1986).Google Scholar
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    778 F.2d 678 (11th Cir. 1985.Google Scholar
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    Id. at 686.Google Scholar
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    768 F.2d 303 (10th Cir. 1985).Google Scholar
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    Id. at 308.Google Scholar
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    The importance of training has been underscored by advisory standards. See ACA/CAC 2-5271, and NCCHC J-58 which require training concerning the recognition of signs, symptoms, behavioral clues disturbance or suicide.Google Scholar
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    No liability: Chinchello v. Fenton, 805 F.2d 126, 134 (3d Cir. 1986),Kriskop v. Oswald, 655 F. Supp. 1476, 1652 (E.D. Pa 1987);liability: Voutour v. Vitale, 761 F.2d 812 (1st Cir. 1985); Kentucky v. Rymer, 754 F.2d 756 (6th Cir. 1985).Google Scholar
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    107 S.Ct. 1114 (1987).Google Scholar
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    Id. at 1121.Google Scholar
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    Civ. Action No. Har-84-827 (D. Md. 1988); the court noted that there had not been a suicide at the facility in 12 years.Google Scholar
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    Of note is data in New York state indicating a sharp decline in sucides in police lock-ups since the state instituted a large scale training program to detect suicidal tendencies. Reported in Criminal Justice Newsletter, V.19, No.12, p.2 June 15, 1988.Google Scholar
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    Note that inKanayurak, 677 P.2d 893 (Alaska, 1984) the cell had a video monitor but that it was partially blocked by a metal bar so that visibility in the upper 2/3 of the cell was poor. Thus, even though the decedent was hanging, it looked to the dispatcher as though she were sitting down. A related question to that raised in the text is whether liability can be imposed for design defects. For a review of this and other design considerations see R. Atlas, “Reducing the Opportunity for Inmate Suicide,” 1988.Google Scholar
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    648 F. Supp. 126 at 130.Google Scholar
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    639 F. Supp. 377 (E.D. Pa. 1986).Google Scholar
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    Note thatCALEA Standard 72.9.4 of the Standards Manual of the Law Enforcement Agency Accreditation Program (1983) requires an audio communication system between a designated control point and the arrestee living areas.Google Scholar
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    839 F.2d 240 (6th Cir. 1988).Google Scholar
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    (U.S.D.C. District of Colorado, C.A. # 83-2-222). See also,Jail Suicide Update, published by the Jail Suicide Prevention Information Task Force (SPRING 1987).Google Scholar
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    MASS.GEN.L. CH.40, S.36B.Google Scholar
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    499 N.E. 2d 842 (Mass. Appeals Ct. 1986).Google Scholar
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    Partridge v. Two Unknown Police Officers, 751 F.2d 1448 (1985).Google Scholar
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    See Overby v. Wille, 411 So.2d 1331, 1334 (Fla. App. 1982) in overturning a district court finding of summary judgement, the 4th District Court of Appeals stated: “... the evidence show that the sheriff's department has personnel trained in recognizing the symptoms of mental illness. No such individual was consulted in regard to Overby's condition.”See also, Partridge, 751 F.2d at 1451 in which the court noted: “The jailor was unaware that Partridge's clinical record showed that Partridge had attempted suicide during an earlier confinement. The records were maintained four doors away from the booking desk.Google Scholar
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    768 F.2d 303 (10th Cir. 1985).Google Scholar
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    See Sudderth v. White, 621 S.W.2d 33 (Ky.Ct.App. 1981) which stated that where the jailor knew the decedent had previously cut his wrists a genuine issue of material fact existed as to whether he breached his duty to exercise reasonable care by failing to remove the prisoners belt.See also, Belen v. Harrell, 603 P.2d 711 (N.M. 1979). In that case a juvenile detainee housed in an adult lock-up had been stripped to his shorts and placed in a cell. When his mother came to visit he was allowed to put his clothing on. At the visit the son attempted to slash his wrist with a flip-top from an aluminum can. He also told his mother not to come back the next day because she would not see him alive. The custodians who were aware of both the act and the statement, failed to remove the boys clothing before placing him back in a cell. He was subsequently found dead hanging from a vent by his shirt sleeve.Google Scholar
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    839 F.2d 240 (6th Cir. 1988).Google Scholar
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    Standard J-58.Google Scholar
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    Cohen writes: “Where clinical judgement so dictates, the use of temporary isolation along with regular observation to deal with the acting-out inmate will not likely create any legal problems” Cohen, F. Legal Issues and the Mentally Disordered Inmate,1985 Sourcebook on the Mentally Disordered Prisoner 61.Google Scholar
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    See, Belen v. Harrell, 93 N.M. 601, 603 P.2d 711 juvenile confined in adult lock-up, knowledge of attempted suicide, hanging by shirt sleeve; Overby v. Wille, 411 So. 2d 1331 (D.C. of App. Fla. 4th dist.), history of mental illness; suicide hanging by belt; Sudderth v. White, 621, S.W.2d. 33 (CofA Kentucky 1981), knowledge of previous suicide; hanging by belt; Miga v. City of Holyoke, 497 N.E.2d 1 (Mass. 1986), knowledge of previous suicide attempts, intoxicated, suicide hanging by sweatshirt; Falkenstein v. City of Bismark, 268 N.W.2d 787 (N.D. 1978), intoxicated, hanging by T-shirt.Google Scholar
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    See, Miga v. City of Holyoke, 398 Mass. 342, 497 N.E.2d 1 (1986), Garcia v. Salt Lake County, 768 F.2d 303 (10th Cir. 1985), and Anderson v. Atlanta, 778 F.2d 678 (11th Cir. 1985).Google Scholar
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    SeeJail Suicide Update ((Summer 1987), p. 2 re “Suicide Prevention Screening”: “Those individuals that refuse ... screening or are unable (due to their intoxication) to participate, should be temporarily housed in the cellblock and placed under special supervision until such time as intake screening can be completed.”Google Scholar
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    ACA/CAC 2-5174, CALEA 72.10.3But see Standard J-58 of NCCHC which would prohibit isolation of any suicidal inmate unless constant supervision can be maintained. If such is not the case then “... she should be housed with another resident or in a dormitory and checked every ten to fifteen minutes.”Google Scholar
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    Mass.Gen.L. ch.40 S.36B (1986).Google Scholar
  117. 125.
    Gordon v. City of New York (NY Ct. App. 1987).Google Scholar
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    402 Mass. 190 (1988).Google Scholar
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    See Mass.Gen.L.ch.123,s.21.Google Scholar
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    See Williams v. City of Lancaster, 639 F.Supp. 377 (E.D.Pa. 1986) in which the court indicated that the failure to follow state regulations requiring medical examinations of all “suspected inebriates” was merely negligence and did not indicate deliberate indifference or a constitutional violation.”Also see, Delasky v. Hinsdale, 441 N.E.2d 367 (Ill.App.2d.1983) where the court stated that violation of a police regulation governing search was “prima facie evidence of negligence but that it could be rebutted by proof that the party acted reasonably under the circumstances despite the violation.Google Scholar
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    497 N.E.2d at 3.Google Scholar
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    See Falkenstein v. Bismark, 268 N.W.2d at 794, in which the court upheld a finding of punitive damages stating that the jury might have found that placement of the decedent in “the hole” was prompted by anger on the officer's part.Google Scholar
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    See, Miga v. City of Holyoke, 497 N.E.2d at 4.Also see Kanayurak v. North Slope Borough, 667 P.2d 893, 895 (Alaska 1984): “Prior to her suicide, Kanayurak had been screaming that someone should locate and check on her two children ... Because her screaming and shouting was disrupting work in the office, Director of Public Safety Moeller closed the door to the cell area to muffle the noise.”Also see Molton v. City of Cleveland, 839 F.2d 240, 242 (6th Cir. 1988): “As Molton, using his shirt, was attempting to rig a noose in order to hang himself from the upper part of the cell, Carlin Roe (another detainee) began shouting loudly for help. Moulton failed at his first effort to hang himself because his shirt tore; however, upon the second attempt he was successful and ended his life ... Although (other detainees) heard the shouts for help from the booking area, no officer responded.”Google Scholar
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    597 P.2d 58, 63 (Mont, 1079) (Shea, J., dissenting).Google Scholar
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    In “Custodial Suicide Cases: an Analytical Approach to Determine Liability for Wrongful Death,” (62 B.U.L.Rev. 177, 194–203, at 196) Braunstein writes that in their determination of liability “courts must consider differences both among types of custodial institutions and among institutions of the same type.”Google Scholar
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    604 P.2d 1198, 1204 (Hawaii, 1979).Google Scholar
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    Consider ACA/CAC standards for Adult Detention Facilities (range of population) as well as NCCHC “Jail Health Care Services.”Google Scholar
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    See Cohen, F., Legal Issues and the Mentally Disordered Inmate,1985 Sourcebook on the Mentally Disordered Prisoner 48–73.Google Scholar
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  • William D. O'Leary

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