Leroy Leftwich v. County of Dakota, 9 F.4th 966

Background

Cameron Leftwich was arrested for allegedly assaulting his girlfriend and transported to Dakota County jail; the girlfriend and his mother reported anger and past self-harm but did not report suicidal intent.
Eagan Sgt. Wegner completed an Offender Tracking Form (OTF) marking "no" to mental-health/suicide questions; Officer Rundquist observed Cameron and heard no admissions of self-harm.
At jail intake Deputies Kocher and Themmes asked Cameron about suicidal thoughts; Cameron denied suicidal ideation but reported a "dual disorder." A contract nurse scheduled a mental-health visit within 72 hours; a county social worker (Swanson) who typically sees "score 1" inmates within 24 hours did not see Cameron due to limited hours.
Cameron was placed in a housing unit with 25-minute well-being checks and was found hanging in his cell the same night; resuscitation failed and he died.
Leftwich sued under 42 U.S.C. § 1983 (failure to provide adequate medical care; failure to train) and under Minnesota wrongful-death law; the district court granted summary judgment for defendants and denied Leftwich leave to amend; the Eighth Circuit affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
§1983 — deliberate indifference / inadequate medical care	Leftwich: officers/deputies knew or should have known of suicide risk from victim's and mother's statements and Cameron's mental-health history; therefore they were deliberately indifferent.	Defendants: no one had actual knowledge of a substantial suicide risk; Cameron denied suicidal ideation and behaved normally; routine arrest and "dual disorder" do not establish substantial risk.	Affirmed: no genuine dispute that any defendant was subjectively aware of a substantial suicide risk; no constitutional violation.
§1983 — municipal liability / failure to train	Leftwich: City/County training/practices led to inadequate response to suicide risk, showing deliberate indifference.	City/County: absent an underlying constitutional violation by employees, Monell liability cannot attach; no evidence of deliberate indifference in training.	Affirmed: because no employee was deliberately indifferent, municipalities cannot be liable for failure to train.
Minnesota wrongful-death — public-official immunity for Sgt. Wegner and Swanson	Leftwich: their duties were ministerial (e.g., completing OTF or meeting inmates within 24 hours), so immunity does not apply.	Defendants: answering OTF mental-health items and Swanson's decisions are discretionary judgments, not ministerial.	Affirmed: both officers performed discretionary functions and are entitled to official-immunity absent willful or malicious conduct.
Minnesota public-entity (statutory) immunity re County mental-health policy	Leftwich: County failed to implement its mental-health screening practices (24-hour vs. 72-hour), so immunity doesn't apply.	County: decision to schedule a nurse visit within 72 hours is a policy/planning decision and thus statutorily immune; Swanson was not required by policy to see Cameron within 24 hours.	Affirmed: the County's scheduling/contract decisions were planning-level and immune; no evidence County deviated from policy.
Denial of motion to amend scheduling order	Leftwich: sought leave to amend after deadline, claiming diligence and new facts from depositions.	Defendants: Leftwich failed to show good cause under Rule 16(b) and delayed taking basic depositions of known parties.	Affirmed: district court did not abuse discretion in denying leave for lack of diligence/good cause.

Key Cases Cited

Monell v. Dep't of Soc. Servs., 436 U.S. 658 (1978) (municipal liability principles under § 1983)
City of Canton v. Harris, 489 U.S. 378 (1989) (failure-to-train municipal liability standards)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires subjective awareness of substantial risk)
A.H. v. St. Louis County, 891 F.3d 721 (8th Cir. 2018) (Eighth Circuit standard for jail suicide claims)
Bell v. Stigers, 937 F.2d 1340 (8th Cir. 1991) (knowledge threshold in jail-suicide failure-to-protect claims)
Szabla v. City of Brooklyn Park, 486 F.3d 385 (8th Cir. 2007) (deliberate indifference and municipal liability discussion)
Bd. of Cnty. Comm'rs v. Brown, 520 U.S. 397 (1997) (limits on municipal liability absent policy or directive)
Hott v. Hennepin County, 260 F.3d 901 (8th Cir. 2001) (routine arrest/detention does not, by itself, indicate suicide risk)
Vassallo ex rel. Brown v. Majeski, 842 N.W.2d 456 (Minn. 2014) (Minnesota public-official immunity analysis)
Freeman v. Busch, 349 F.3d 582 (8th Cir. 2003) (Rule 16(b) good-cause requirement for untimely amendments)
Popoalii v. Correctional Medical Servs., 512 F.3d 488 (8th Cir. 2008) (abuse-of-discretion standard for amendment denials)
In re Milk Prods. Antitrust Litig., 195 F.3d 430 (8th Cir. 1999) (district court discretion in case-management and amendment decisions)