Estate of Stevens ex rel. Collins v. Board of County Commissioners
53 F. Supp. 3d 1368
D.N.M.2014Background
- Stevens was arrested and incarcerated at SJCADC on an aggravated battery charge (April 15, 2012).
- CHC provided medical/mental health services at SJCADC with knowledge of Stevens’s mental health history.
- A Jane Doe completed an intake that noted prior suicide attempts and mental health diagnoses, and Stevens was placed on “observation for mental health” before later being housed in general population.
- Stevens reported anxiety on April 28, 2012; on April 29, 2012, he hanged himself in a bathroom stall.
- Estate filed suit in September 2013 naming CHC and unnamed “Correctional Officer Defendants”; Counts I and II arise under 42 U.S.C. § 1983, alleging deliberate indifference and failure to train/supervise; CHC moved to dismiss in August 2014, which the court converted to a Rule 12(c) judgment on the pleadings.
- The court granted in part, dismissing Count I as to CHC-employed Officer Defendants and Count II as to CHC, with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether CHC-employed Officer Defendants can be held liable under Count I. | Plaintiff asserts CHC employees acted with deliberate indifference. | CHC argues lack of specific allegations against individual officers and insufficient notice. | Count I against CHC-employed Officer Defendants dismissed for lack of notice and specificity. |
| Whether Count I adequately alleges deliberate indifference by CHC employees. | Plaintiff alleges officers knew of suicide risk and failed to provide care. | Plaintiff fails to plead specific wrongful acts/omissions by individual officers. | Count I dismissed for failure to plead the requisite acts/omissions and causal link. |
| Whether Count II (failure to train/supervise) states a claim against CHC. | Allegations imply CHC policies/training deficient with respect to at-risk inmates. | Plaintiff must show a direct causal link between policy/custom and violations; lacking evidence of acts. | Count II dismissed for lack of showing of a CHC policy/custom driving the violations. |
Key Cases Cited
- Robbins v. Oklahoma, 519 F.3d 1242 (10th Cir. 2008) (notice requirement for § 1983 claims against multiple defendants must specify each actor's acts)
- Brown v. Montoya, 662 F.3d 1152 (10th Cir. 2011) (individualized pleadings required when defendants have different duties/tasks)
- Gray v. University of Colorado Hospital Authority, 672 F.3d 909 (10th Cir. 2012) (collective terms without attribution fail to provide fair notice)
- VanZandt v. Oklahoma Department of Human Services, 276 F.App’x 843 (10th Cir. 2008) (collective-defendant pleadings improper; fair notice required)
- Kentucky v. Graham, 473 U.S. 159 (1985) (official-capacity claims require showing CHC as moving force behind violation)
- Estelle v. Gamble, 429 U.S. 97 (1976) (serious medical needs standard for deliberate indifference)
- City of Canton v. Harris, 489 U.S. 378 (1989) (failure to train requires a causal link to a policy or custom)
- Dalcour v. City of Lakewood, 492 Fed.Appx. 924 (2012) (unpublished; requires showing policy/custom driving violation)