Norman Whitney, Sr. v. City of St. Louis, Missouri, 887 F.3d 857

Norman Whitney Jr., a pretrial detainee with recent suicidal ideation and multiple medical conditions, was admitted to the St. Louis City Justice Center and placed in a CCTV-monitored medical cell on August 10, 2014.
Correctional officer Shelley Sharp was assigned to monitor Whitney via closed-circuit television; she last observed him alive at 9:05 a.m. and discovered he had hanged himself within the next 14 minutes.
A medical examiner’s report indicated an unnamed Justice Center medical practitioner had been told of Whitney’s suicidal thoughts, but the complaint alleges no facts showing that Sharp or other named jail personnel received that information.
Whitney Sr. sued Sharp (individually and officially) and the City of St. Louis under 42 U.S.C. § 1983 (deliberate indifference re: suicide risk) and asserted state wrongful-death claims; the case was removed to federal court.
The district court dismissed the § 1983 claims with prejudice for failure to plead deliberate indifference and dismissed the state-law claims without prejudice; the Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sharp was deliberately indifferent to a known suicide risk	Whitney Sr. argued Sharp failed to adequately monitor, provide medical care, or intervene, causing death	Sharp argued complaint lacks allegations showing she had actual knowledge of Whitney’s suicide risk	Dismissed: complaint fails the subjective knowledge element of deliberate indifference (no factual allegations that Sharp knew of suicidal ideation)
Whether the City is liable under Monell absent an underlying constitutional violation	Whitney Sr. argued City’s failure to have a constant-surveillance policy could expose it to municipal liability	City argued Monell requires an underlying constitutional violation by a municipal employee before municipal liability attaches	Dismissed: no Monell liability because plaintiff failed to plead any constitutional violation by Sharp or identifiable municipal policy causing one

Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability requires an unconstitutional policy or custom)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards; conclusory allegations insufficient)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
Coleman v. Parkman, 349 F.3d 534 (Eighth Circuit deliberate indifference to suicide risk rule)
Jackson v. Buckman, 756 F.3d 1060 (deliberate indifference requires objective and subjective showings)
Malone v. Hinman, 847 F.3d 949 (no Monell liability absent individual constitutional violation)
Szabla v. City of Brooklyn Park, 486 F.3d 385 (lack of a more specific policy does not itself establish municipal liability)