Shelton v. Arkansas Department of Human Services, 677 F.3d 837

Shelton, administratrix of Brenda Shelton’s estate, appeals district court dismissal of federal claims and non-exercise of jurisdiction over state-law claims.
Plaintiff alleges state-law torts, a federal due-process claim, and ADA and Rehab Act claims stemming from Brenda’s death at a state mental health facility.
Brenda admitted voluntarily to Arkansas State Hospital in 2008, placed on suicide watch, later removed from suicide watch by Dr. Parker, three days before Brenda hanged herself.
Nurses allegedly refused mouth-to-mouth resuscitation due to lack of protective shields; rescue equipment was reportedly locked or inaccessible.
Plaintiff asserts facility policies, failures to train staff, and defendant supervisors’ acts/failures contributed to Brenda’s death and increased suffering and medical expenses.
District court dismissed federal claims with prejudice and declined jurisdiction over state-law claims; the appellate court affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did defendants owe a constitutional duty of care to a voluntary patient after discovery of self-harm risk?	Kennedy-like duty arises upon discovery of Brenda’s risk post-admission.	No constitutional duty unless status shifted to involuntary; Kennedy does not extend here.	No duty arose pre-discovery nor post-discovery to create a constitutional-level duty.
Can a constitutional claim be based on emergency medical treatment decisions in this context?	Removal from suicide watch and related decisions may implicate due process.	Kennedy limits; post-emergency treatment decisions do not establish a constitutional duty.	Kennedy cannot be extended; no clearly established constitutional duty.
Are ADA and Rehab Act claims cognizable when grounded in medical treatment decisions?	Claims stem from improper placement/removal from suicide watch and care decisions.	ADA/Rehab Act claims cannot rest on medical-treatment decisions.	Such statutory claims must fail as framed; dismissal proper.
Should the district court have exercised jurisdiction over state-law claims if federal claims were dismissed?	State-law claims may remain viable if federal claims dismissed without prejudice.	Court declines jurisdiction over state-law claims.	Affirmed: federal claims dismissed with prejudice; no jurisdiction over state-law claims.

DeShaney v. Winnebago Cnty. Dep’t of Soc. Servs., 489 U.S. 189 (1989) (State must provide services to ensure safety of involuntarily confined individuals)
Kennedy v. Schafer, 71 F.3d 292 (8th Cir. 1995) (possible conversion of voluntary to involuntary status under certain state laws)
Hott v. Hennepin Cnty., Minn., 260 F.3d 901 (8th Cir. 2001) (treatment decisions linked to medical necessity may underlie medical-treatment claims)
Liebe v. Norton, 157 F.3d 574 (8th Cir. 1998) (suicide risk and medical needs implications under medical-rights framework)
Fields v. Abbott, 652 F.3d 886 (8th Cir. 2011) (addressing notions of clearly established rights in qualified-immunity context)
Burger v. Bloomberg, 418 F.3d 882 (8th Cir. 2005) (ADA/ Rehab Act claims cannot be based on medical-treatment decisions)
Schiavo ex rel. Schindler v. Schiavo, 403 F.3d 1289 (11th Cir. 2005) (statutory claims related to medical treatment decisions)