Court expands the rights of pre-trial detainees who were denied proper medical treatment

The Court of Appeals has revived a civil rights case alleging that jail officials in Putnam County were deliberately indifferent to a pre-trial detainee who died following a suicide attempt while she was undergoing heroin withdrawal. This case details the rules governing when poor supervision by jail officials may result in liability under Section 1983.

The case is Lara-Grimaldi v. County of Putnam, issued on March 27, more than year following oral argument. The deceased ("plaintiff") entered the County Jail following her arrest for an alleged probation violation and allegedly possessing a hypodermic needle. She told the intake officers that she had recently injected heroin and that she had previously attempted suicide. The officers also knew she was mentally ill. The claim is that, despite this knowledge, the officers were not sufficiently attentive to plaintiff, who hanged herself with a bedsheet in her cell and died after she was taken to the hospital.

The Eighth Amendment prohibits the cruel and inhumane treatment of inmates, but those cases impose a high standard for plaintiffs who were convicted of a crime. Under the Fourteenth Amendment, invoked by pre-trial detainees (not yet convicted of anything), the legal standard is more lenient. The Supreme Court has drawn that distinction, and the Second Circuit developed it further in Darnell v. Pineiro, 849 F.3d 17 (2d Cir. 2017) (a case I briefed on appeal), and Charles v. Orange County, 925 F.3d 73 (2019). Under these cases, the plaintiff wins if the correction officer was deliberately indifferent to jail conditions and acted intentionally to impose the jail condition or recklessly failed to act with reasonable care to mitigate the risk to the inmate. If the defendant knew or should have known the condition posed an excessive risk to the plaintiff, then the Fourteenth Amendment is violated.

The Court of Appeals extends Darnell to cases like this, where the officers, aware of an excessive health risk, do not properly supervise the plaintiff. While Darnell involved prison conditions (bad toilets, overcrowding, vermin, etc.), the Second Circuit (Kearse, Leval and Nardini) says its reasoning "is equally applicable to due process claims for denial of medical care." This is a civil rights victory for inmates and their lawyers.This case will proceed to trial because defendants were aware of plaintiff's risk of experiencing withdrawal symptoms, her bipolar disorder, and her prior suicide attempt. As the jury may find these defendants failed to properly supervise plaintiff and that failure led to her death, summary judgment is reversed.