Nichole Sanchez v. Young County, Texas, et
2017 U.S. App. LEXIS 13886
| 5th Cir. | 2017Background
- Diana Simpson, with history of depression and a prior suicide attempt, was found asleep in her car after withdrawing cash and admitting (to arresting officer) she had taken multiple pills and drank alcohol; she was arrested for public intoxication and booked into Young County Jail.
- Medics examined Simpson at the scene, recorded essentially normal vitals, and she declined transportation to a hospital; she denied suicidal intent during multiple questioning events.
- At booking, the jail intake medical screening was incompletely filled; staff did not run a state Continuity of Care Query (CCQ); monitoring frequency while detained is disputed and another detainee was placed in the same holding cell.
- Husband repeatedly called police and the jail, warning she was a suicide risk and requesting medical or mental-health help; jail staff told him MHMR would not assist until she was sober.
- Simpson was found unresponsive in the cell ~8 hours after arrest and later died; autopsy found mixed drug intoxication consistent with probable suicide.
- Plaintiffs sued Young County under 42 U.S.C. § 1983 alleging (1) unconstitutional conditions of confinement (UCC) and (2) episodic acts and omissions (EA/O) by jailers; district court granted summary judgment for County on all § 1983 claims; Fifth Circuit affirmed dismissal of EA/O claim but vacated/remanded UCC claim for further consideration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether County liable under EA/O theory for jailers’ conduct causing Simpson’s death | Simpson’s family: jailers were subjectively deliberately indifferent to a known risk (admissions, pills, husband’s warnings) and County policies/customs (incomplete intake, lack of CCQ, inadequate monitoring/training) causally led to death | County: actions amounted to negligence at most; intake was substantially completed, medics saw no emergency, no evidence of municipal custom or causal link, sheriff had no personal involvement | Affirmed: plaintiffs failed to show subjective deliberate indifference by employees or an objectively indifferent municipal policy causally linked to death under EA/O theory |
| Whether County liable under UCC theory for unconstitutional pretrial-detention conditions that caused death | Plaintiffs: policies/procedures (screening, monitoring, training) created unconstitutional conditions contributing to death | County: no systemic policy shown; single incident insufficient; no causal proof that policy failures caused death | Vacated and remanded: district court must consider in first instance whether genuine fact issues exist on UCC claim |
| Whether County can be held liable via respondeat superior / supervisor liability | Plaintiffs: County liable for customs/policies adopted or tolerated by Sheriff and jail administration | County: no respondeat superior in § 1983; Sheriff had no personal involvement before death | Court: Monell bars respondeat superior; supervisor liability requires personal involvement; no liability based solely on Sheriff’s lack of prior knowledge (but UCC remand could examine Sheriff’s role) |
| Sufficiency of evidence to survive summary judgment standard | Plaintiffs: record (arrest report, husband’s calls, sheriff’s deposition, inspection noncompliance) creates genuine disputes of material fact | County: record shows no subjective inference of risk and no municipal custom; evidence is insufficient as a matter of law | Mixed: Majority finds evidence insufficient on EA/O; concurrence dissents and argues the record creates genuine factual disputes requiring trial |
Key Cases Cited
- Hare v. City of Corinth, 74 F.3d 633 (5th Cir. 1996) (distinguishes municipal liability theories: episodic acts v. unconstitutional conditions)
- Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (1978) (municipal liability under § 1983 cannot rest on respondeat superior)
- Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (summary judgment standard: genuine issue for trial requires sufficient evidence for a jury)
- Shepherd v. Dallas County, 591 F.3d 445 (5th Cir. 2009) (distinguishing systemic medical-care claims from isolated employee failures)
- Lawson v. Dallas County, 286 F.3d 257 (5th Cir. 2002) (discusses municipal liability and constructive notice in certain § 1983 contexts)
- Estate of Henson v. Wichita County, 795 F.3d 456 (5th Cir. 2015) (articulates subjective-deliberate-indifference standard for episodic acts by jail officials)
- Alderson v. Concordia Parish Corr. Facility, 848 F.3d 415 (5th Cir. 2017) (clarifies deliberate-indifference concepts relevant to custody and episodic-act claims)