Reginald Pittman v. County of Madison, Illinois, 2014 U.S. App. LEXIS 4444

Pittman, a pretrial detainee at Madison County Jail, attempted suicide by hanging from his cell bars on Dec 19, 2007, causing severe brain injury.
CRISIS mental health services (Chestnut Health Systems) evaluated Pittman in Oct 2007; records showed no suicidal ideation then, but notes indicated anxiety and housing stress.
Pittman was placed on various housing arrangements, including segregation-like settings and SHU, with intermittent CRISIS referrals and medical evaluations by Nurse Unfried and Dr. Blankenship.
Banovz, Pittman’s cell neighbor, testified that Deputy Werner and Sergeant Eaton ignored Pittman’s CRISIS requests and signs of distress preceding the suicide attempt; Eaton and Werner deny ignoring those requests.
Jail policies required reporting CRISIS requests and assessing suicide risk, but allowed officer discretion in addressing concerns and determining placement on suicide watch.
District court granted summary judgment for most defendants; the Seventh Circuit reversed on the Werner/Eaton claims, remanding for further proceedings, and affirmed summary judgment as to others; the county and sheriff faced potential state-law liability only for actions of subordinates.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Werner and Eaton were deliberately indifferent to Pittman’s risk.	Banovz’s testimony shows Pittman cried and sought CRISIS; officers ignored requests.	Requests alone are not sufficient to show imminent risk; Collins controls.	Yes, genuine issue of material fact; remand for further proceedings.
Whether Unfried and Blankenship acted with deliberate indifference in medical care.	Medical staff failed to monitor and respond adequately to Pittman’s distress.	Care and medications were provided; no evidence of deliberate indifference.	No, not shown to meet deliberate indifference standard.
Whether Sheriff Hertz and Captain Gulash were deliberately indifferent due to jail policies.	Policies were inadequate in preventing suicides; widespread failures show deliberate indifference.	Policies were in place and training occurred; no showing of cognizable deliberate indifference by them.	Summary judgment proper for these defendants.
Whether the county and sheriff can be held liable under Illinois state law for willful and wanton conduct.	Failure to implement adequate protocols constitutes willful and wanton disregard.	Willful and wanton standard mirrors deliberate indifference; insufficient proof.	If Werner/Eaton are deliberate indifferent, state-law liability may attach; need further fact-finding.

Collins v. Seeman, 462 F.3d 757 (7th Cir. 2006) (deliberate indifference requires awareness of substantial risk and action taken; mere request to see crisis counselor is insufficient)
Estate of Novack ex rel. Turbin v. County of Wood, 226 F.3d 525 (7th Cir. 2000) (requires cognizable risk and failure to act; proximate causation matters)
Higgins v. Corr. Med. Servs. of Ill., Inc., 178 F.3d 508 (7th Cir. 1999) (deliberate indifference standard for detainees similar to inmates)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (test for subjective awareness of substantial risk in deliberate indifference)
Belbachir v. County of McHenry, 726 F.3d 975 (7th Cir. 2013) (limits liability where supervisor knowledge is not shown)
Thomas v. Cook County Sheriff’s Department, 604 F.3d 293 (7th Cir. 2010) (caution against bright-line rules; requires policy failure to show constitutional violation)
Collignon v. Milwaukee County, 163 F.3d 982 (7th Cir. 1998) (damages and duties of detainees; limits on Monell-type liability absent policy evidence)
Gordon v. Degelmann, 29 F.3d 295 (7th Cir. 1994) (unidentified officers can still subject municipality to liability; identifies limits of respondeat superior)
Williams v. Rodriguez, 509 F.3d 392 (7th Cir. 2007) (unidentified officer liability against municipality for rights violations)