Sharyn Haynes v. Wayne County, Tennessee
M2016-01252-COA-R3-CV
| Tenn. Ct. App. | Apr 19, 2017Background
- Philip Haynes (20) was arrested July 17, 2010 for public intoxication/related offenses, transported to Wayne County Jail after appearing extremely intoxicated and making suicidal statements on arrival.
- During booking Haynes reported prior suicide attempts and depression; he was placed on suicide watch and put in a safety suit under Officer Dugger’s supervision.
- Centerstone had a mobile crisis team available to the jail but did not evaluate intoxicated persons; Dugger did not call Centerstone because Haynes’s threats occurred while he was highly intoxicated.
- At shift change Officer Sanders was told of the prior suicidal statements; Sanders asked Haynes whether he remembered the threats, and Haynes (per Sanders) said, jokingly, he was just drunk and didn’t mean it.
- Sanders processed and released Haynes at ~9:30 a.m.; Haynes was later picked up by family, appeared possibly intoxicated to his grandmother but not obviously so to his cousin, and fatally shot himself around 11:49 a.m.
- Plaintiff (grandmother) sued Wayne County under Tennessee’s Governmental Tort Liability Act for wrongful death, alleging negligent release without mental-health evaluation or family notification; the trial court granted summary judgment for the County and Plaintiff appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to bring wrongful-death suit | Grandmother (Haynes) is a statutorily authorized beneficiary and may proceed; no superior beneficiary has objected. | County argued possible superior beneficiaries (father, adoptive father, half-brother) exist so plaintiff lacks standing. | Haynes has standing; absent any superior beneficiary asserting control or objection, an inferior beneficiary may proceed. |
| Existence/scope of duty arising from custodial relationship | County assumed heightened duty when Haynes made suicidal statements; that duty continued to release if risk remained. | County argued its custodial duty ended at release and thus no duty at time of suicide. | Court: custodial duty arose when County took Haynes into custody and can give rise to liability for post-release harm if breach occurred during custody; but duty’s scope depends on foreseeability at release. |
| Breach of duty (failure to call Centerstone/notify family; premature release) | County breached heightened duty by releasing Haynes without mental-health evaluation/notification while intoxicated and suicidal. | County: Haynes disavowed suicidal intent to Officer Sanders, appeared fine; Centerstone wouldn’t evaluate intoxicated persons; release was reasonable. | No genuine factual dispute showing breach; Haynes’s disavowal (per Sanders) and Centerstone policy undercut plaintiff’s expert opinion; summary judgment for County affirmed. |
| Proximate cause (was release a substantial factor in suicide?) | Release without evaluation/notification was a substantial factor in the suicide. | County: suicide was an independent, voluntary intervening act by an adult who understood consequences; not foreseeable at release. | Suicide was not shown to be a foreseeable or substantially caused result of County’s conduct; intervening voluntary act broke causal chain. Summary judgment affirmed. |
Key Cases Cited
- Abshure v. Methodist Healthcare–Memphis Hosps., 325 S.W.3d 98 (Tenn. 2010) (standard of review for summary judgment in Tennessee)
- Rye v. Women’s Care Ctr. of Memphis, MPLLC, 477 S.W.3d 235 (Tenn. 2015) (nonmoving party must present specific facts to survive summary judgment)
- White v. Lawrence, 975 S.W.2d 525 (Tenn. 1998) (suicide as intervening act that can break causation)
- Cockrum v. State, 843 S.W.2d 433 (Tenn. Ct. App. 1992) (custodial duty and protection of inmates from foreseeable self‑harm)
- Atkinson v. State, 337 S.W.3d 199 (Tenn. Ct. App. 2010) (prison officials’ duty is ordinary care; duty expands when officials know or should know prisoner might self‑harm)
- Coscia v. Town of Pembroke, 659 F.3d 37 (1st Cir. 2011) (discussed re: liability for post‑release suicide and causation)
- Clemets v. Heston, 485 N.E.2d 287 (Ohio Ct. App. 1985) (custodial duty ends at release but causation remains the operative inquiry)