Randi Hyatt v. Callahan County
2016 U.S. App. LEXIS 20722
| 5th Cir. | 2016Background
- Jason Hyatt was arrested for suspected DUI and booked into Callahan County jail after his wife notified jailer/dispatcher Brianna Thomas that he was suicidal and had prior suicide attempts.
- During booking Thomas (trained in suicide assessment) completed a screening: Hyatt admitted past attempts, depression, and improper use of antidepressants but denied current suicidal intent; Thomas noted intoxication and withheld thin sheets/hygiene items because of his history.
- Hyatt was placed in a video-surveilled cell with a blind spot at the toilet; Thomas informed the relieving jailer of Hyatt’s history and instructed vigilance.
- Overnight jailers checked on Hyatt; one observed no suicidal indicators. Around 8:02 a.m., a jailer found Hyatt hanged with a plastic garbage bag; EMS pronounced him dead.
- Hyatt’s family sued under 42 U.S.C. § 1983 alleging deliberate indifference to a known suicide risk; the district court granted summary judgment to Thomas based on qualified immunity; the Hyatts appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Thomas was subjectively aware of a substantial suicide risk | Thomas knew of Hyatt’s prior attempt, depression, and received wife’s warning — so she knew of significant risk | Thomas asserts she did not consider Hyatt an imminent suicide risk and lacked knowledge of specific means (plastic bag) | Court: Genuine dispute exists — a jury could find Thomas was subjectively aware of a substantial risk |
| Whether Thomas’s response constituted deliberate indifference | Failing to remove all potential ligatures, inspect cell, and fully follow county suicide policy amounted to deliberate indifference | Thomas withheld obvious ligatures, placed Hyatt on continuous video surveillance, and warned relieving officers — she acted reasonably | Court: Thomas’s measures were reasonable; at most negligent; no deliberate indifference; qualified immunity applies |
| Whether noncompliance with county suicide policy establishes constitutional violation | Plaintiffs argue policy breaches can show deliberate indifference | Thomas contends her actions were adequate despite any policy gaps; county policy’s practical force is unclear | Court: Potential policy lapses would be, at most, negligence given steps Thomas took; not enough for deliberate indifference |
| Whether knowledge of specific instrument is required to establish liability | Plaintiffs say specific means not required—awareness of substantial risk suffices | Thomas urges plaintiff must show she knew the plastic bag was in the cell | Court: Specific knowledge of the instrument is not required per Farmer; only awareness of a substantial risk is necessary |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference to serious medical needs)
- Farmer v. Brennan, 511 U.S. 825 (subjective awareness and reasonableness standard for deliberate indifference)
- Davidson v. Cannon, 474 U.S. 344 (negligence by jail officers does not equal constitutional violation)
- Hare v. City of Corinth, 74 F.3d 633 (due process duty to provide protection and care for pretrial detainees)
- Gobert v. Caldwell, 463 F.3d 339 (deliberate indifference requires disregarding a substantial risk by failing reasonable abatement)
- Domino v. Texas Dep’t of Crim. Justice, 239 F.3d 752 (deliberate indifference is an extremely high standard)