Estate of Rice Ex Rel. Rice v. Correctional Medical Services, 2012 U.S. App. LEXIS 5728

Background

Rice, a pretrial detainee with schizophrenia, died in Elkhart County Jail from acute hyponatremia due to psychogenic polydipsia while awaiting transfer to a psychiatric facility.
CMS provided jail medical services under contract; Oaklawn Psychiatry provided inpatient psychiatric care under contract, with Rohrer and Ceniceros as treating physicians.
Estate sued under §1983 and Indiana state-law claims, alleging deliberate indifference to Rice’s medical/psychiatric needs and inhumane confinement conditions; district court granted summary judgment on federal claims and dismissed state claims via collateral estoppel.
Evidence showed Rice repeatedly refused medications, deteriorated physically, was housed in administrative segregation (Ward One) for months, and suffered from poor self-care and hygiene; multiple officials and nurses intervened at times but did not prevent decline.
Rice died in December 2004 after a night of disputed supervision, following a razor incident and prior episodes suggesting self-destructive behavior; the autopsy linked death to water intoxication from excessive drinking.
This Seventh Circuit panel reversed in part on the §1983 claims, remanded state-law claims, and addressed whether private providers (Oaklawn/Ceniceros) could be treated as state actors and whether a policy/custom claim could support municipal/corporate liability.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rice’s confinement conditions were cruel and inhumane under due process.	Estate asserts deliberate indifference to sanitation and self-care.	District court found conditions were largely self-inflicted and not deliberately indifferent.	Dispute of material fact exists; conditioning deliberateness on self-inflicted conditions is improper.
Whether the prolonged administrative segregation violated due process.	Seven months in Ward One worsened Rice’s mental/physical state; segregation policies were inadequate.	No documented alternatives shown; containment was for monitoring.	Remanded for further consideration; not resolved at summary judgment.
Whether the Pepper-Spray/restraint-chair incident and its handling amounted to excessive force.	Use of pepper spray and 18-hour restraint were excessive and abusive.	Force was applied in good faith to maintain order with limited alternatives.	Summary judgment affirmed against Estate on this claim.
Whether jail failure to protect Rice from inmate assaults established deliberate indifference.	Staff knew of Rice’s vulnerability and failed to prevent attacks.	Insufficient evidence that staff anticipated the specific attacks or that not preventing them violated clearly established standards.	Summary judgment for defendants; no deliberate indifference shown for the assaults.
Whether Rohrer and Ceniceros were state actors liable for deliberate indifference to Rice’s psychiatric needs.	Outsourced private care (Oaklawn) and decisions to withhold/inhibit admission could be state action	Private physicians stay outside state action; medical judgment and patient rights apply; no deliberate indifference proven.	Rohrer and Ceniceros entitled to summary judgment; state-actor status uncertain; no deliberate indifference proved.

Key Cases Cited

Rhodes v. Chapman, 452 U.S. 337 (U.S. 1981) (inmate confinement must provide basic human necessities)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference standard for conditions of confinement)
Helling v. McKinney, 509 U.S. 25 (U.S. 1993) (limits of risk and exposure in confinement contexts)
Gillis v. Litscher, 468 F.3d 488 (7th Cir. 2006) (injury and sanitation standards for detainees)
Vinning-El v. Long, 482 F.3d 924 (7th Cir. 2007) (unsanitary/inhumane confinement for prolonged periods)
Isby v. Clark, 100 F.3d 502 (7th Cir. 1996) (self-care responsibility in confinement context)
Walker v. Shansky, 28 F.3d 666 (7th Cir. 1994) (prolonged segregation may violate Eighth Amendment depending on context)
West v. Atkins, 487 U.S. 42 (U.S. 1988) (private doctors can be state actors when contracted to treat prisoners)
Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816 (7th Cir. 2009) (state-action analysis for private providers under contract)
Pembaur v. City of Cincinnati, 475 U.S. 469 (U.S. 1986) (policies and final policy-makers as basis for liability)
Monell v. Department of Social Services, 436 U.S. 658 (U.S. 1978) (municipal liability requires official policy or custom)
City of Canton v. Harris, 489 U.S. 378 (U.S. 1989) (deliberate indifference in municipal liability; training as policy)
Taylor v. Sturgell, 553 U.S. 880 (U.S. 2008) (preclusion principles; non-party preclusion in federal judgments)