Troutman v. Louisville Metro Department of Corrections

United States Court of Appeals, Sixth Circuit - October 29, 2020 - F.3d - 2020 WL 6336315

Estate and daughter of pretrial detainee who committed suicide while in solitary confinement at correctional facility brought civil rights action against classification officer, facility director and municipality, alleging deliberate indifference.

The United States District Court entered summary judgment in favor of defendants. Daughter appealed.

The Court of Appeals held that:

Genuine issue of material fact as to whether classification officer acted with deliberate indifference to pretrial detainee’s likelihood of suicide precluded summary judgment in favor of officer in detainee’s daughter’s § 1983 action alleging violation of due process following detainee’s suicide; although officer claimed reliance on a medical judgment that detainee no longer presented a suicide risk, the situation did not remain stable between detainee’s initial clearance from medical and his suicide days later, as detainee was involved in altercations that merited his removal to isolation, and medical clearance to general population was not the same as clearance to solitary confinement with access to bedsheets and barred windows.

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