Maria Arenas v. John Calhoun
922 F.3d 616
| 5th Cir. | 2019Background
- At Smith State Prison an officer (Calhoun) on patrol observed inmate Richard Tavara with a bedsheet noose around his neck hanging from a sprinkler head; Calhoun could not see Tavara’s feet through the cell window.
- Calhoun immediately radioed for backup, retrieved a key (initially the wrong key), and awaited additional officers and his supervisor before entry; officers entered roughly seven minutes after the first sighting and Tavara was dead.
- Tavara had a history of severe depression and a prior suicide attempt but was not identified as a suicidal inmate and was classified as Level I (no current mental-health services) at intake to GDOC.
- Plaintiff Arenas (Tavara’s mother) sued under 42 U.S.C. § 1983 alleging Eighth Amendment deliberate indifference; she relied in part on a GDOC suicide-response SOP that she said required immediate cutting down of hanging inmates.
- The district court granted summary judgment for Calhoun, and the Fifth Circuit affirmed, holding Calhoun’s actions were not deliberate indifference but a reasonable response to safety risks and consistent with applicable prison practice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Calhoun’s seven‑minute delay in entering the cell amounted to Eighth Amendment deliberate indifference to a known suicide risk | Arenas: policy and custom required immediate cutting down and CPR; waiting violated SOP and showed wanton disregard | Calhoun: he reasonably feared ambush, followed security practice to wait for backup and supervisor, called for help promptly | Held: No deliberate indifference; waiting for backup and supervisor was reasonable under the circumstances |
| Whether violation of GDOC SOP VG68‑0001 establishes deliberate indifference | Arenas: SOP mandates immediate action and any noncompliance evidences deliberate indifference | Calhoun: SOP applies to inmates previously identified as suicidal/placed in stabilization units; not applicable here | Held: SOP did not apply to Tavara’s status; failure to follow that SOP (as framed) does not show deliberate indifference |
| Whether prior knowledge of Tavara’s suicidal tendencies existed such that Calhoun had subjective culpability | Arenas: Tavara had depressive history and prior attempt (argued to inform culpability) | Calhoun: he lacked subjective knowledge of Tavara’s suicide risk before discovering the hanging | Held: Calhoun lacked prior subjective knowledge; the claim turns on his on‑scene response, not failure to anticipate |
| Whether officers’ conduct was so negligent/grossly negligent that summary judgment was improper | Arenas: other jurisdictions denied QI in faster‑response cases; similar delay can support jury finding | Calhoun: courts give deference to security judgments; prompt radio calls and adherence to procedure negate deliberate indifference | Held: Response was reasonable in light of safety risks; negligence or gross negligence alone does not satisfy the deliberate‑indifference standard |
Key Cases Cited
- Bucklew v. Precythe, 139 S. Ct. 1112 (2019) (Eighth Amendment principles on cruel and unusual punishment)
- Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference standard for medical care)
- Farmer v. Brennan, 511 U.S. 825 (1994) (prison officials’ duty and deliberate indifference framework)
- Gobert v. Caldwell, 463 F.3d 339 (5th Cir. 2006) (elements of deliberate indifference in detention context)
- Jacobs v. W. Feliciana Sheriff’s Dep’t, 228 F.3d 388 (5th Cir. 2000) (distinguishing prevention of future suicide from response to active emergency)
- Longoria v. Texas, 473 F.3d 586 (5th Cir. 2006) (no constitutional duty for unarmed officials to endanger themselves)
- Grogan v. Kumar, 873 F.3d 273 (5th Cir. 2017) (denial of aid over prolonged period supported deliberate‑indifference claim)