Johnson v. Mason County
3:14-cv-05832
| W.D. Wash. | Feb 27, 2017Background
- Plaintiff Peggy Johnson sued Mason County, Healthcare Delivery Systems (HDS), ARNP Aimee Wagonblast, and others under 42 U.S.C. § 1983 and state negligence after her grandson Jimi Johnson, a seriously mentally ill detainee, committed suicide in the Mason County Jail in April 2013.
- Jimi had a documented history of schizoaffective disorder/schizophrenia, prior suicide attempts, multiple recent hospitalizations, and family warnings that he was suicidal; jail and contracted medical staff received some but inconsistent information about his condition.
- HDS employees reviewed records and treated Jimi in jail; Wagonblast met him on March 11, 2013, and the record shows both awareness of psychosis/suicidality and medication changes (discontinuing Haldol and prescribing Zoloft).
- Jail staff placed Jimi in maximum-security housing after an assault; family observed worsening condition and warned jail personnel shortly before he hanged himself.
- Defendants moved for summary judgment arguing lack of actual knowledge/deliberate indifference, qualified immunity for individual officers, and no municipal (Monell) policy or practice causing the claimed constitutional violation; HDS also moved on medical negligence and Monell grounds.
- The court denied all summary judgment motions (including plaintiff’s partial summary judgment motion), finding disputed factual issues about knowledge, deliberate indifference, and institutional practices made this a jury case; it dismissed HDS’s Monell claim and dismissed a duplicative official-capacity defendant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eighth Amendment deliberate indifference by jail staff | Peggy: jail and medical staff knew or should have known Jimi was suicidal and failed to provide adequate care/suicide prevention | County: Jimi denied suicidal intent; staff lacked actual knowledge; individual officers entitled to qualified immunity | Denied — factual disputes on knowledge and reasonableness preclude summary judgment; qualified immunity denied |
| Monell municipal liability (county) | Peggy: county policies/practices reflected deliberate indifference (failure to suicide-watch, leaving means, pattern of inaction) | County: no policy/custom causing violation; merely employing wrongdoer insufficient | Denied — record supports jury could find a policy/practice of deliberate indifference |
| HDS/Wagonblast § 1983 liability | Peggy: HDS and Wagonblast were aware of psychosis/suicidality and acted unreasonably (med change, inadequate supervision) | HDS/Wagonblast: no evidence of acute suicide risk; treatment decisions were reasonable | Denied — reasonableness is a jury question; factual disputes exist |
| Medical negligence expert qualification | Peggy: HDS’s expert (RN) is not qualified to opine about an ARNP’s standard of care; thus Wagonblast lacks admissible expert to defeat negligence claim | HDS: expert (Pearson) is qualified based on experience; admissibility is for the court but credibility/weight go to cross-examination | Denied (to plaintiff’s motion) — court allows the RN expert to testify; qualifications affect weight not admissibility; factual disputes remain |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
- Celotex Corp. v. Catrett, 477 U.S. 317 (movant’s initial burden on summary judgment)
- Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (municipal liability requires policy/custom)
- City of Canton v. Harris, 489 U.S. 378 (municipal liability for failure to train/inaction and deliberate indifference)
- Brosseau v. Haugen, 543 U.S. 194 (qualified immunity and reasonableness of official action)
- Pearson v. Callahan, 553 U.S. 223 (qualified immunity framework)