Silvera v. Corrections
3:09-cv-01398
| D. Conn. | Mar 14, 2012Background
- This case arises from the suicide of pretrial detainee Andre Lyle while in Garner Correctional Institute custody.
- Plaintiff, as administratrix of Lyle’s estate, sues Dr. Gasparo and Counselor Samson (medical staff) and Officers Standish and Swan (custody staff) for cruel and unusual punishment and related claims.
- Lyle had a long history of depression and prior suicide attempts, was classified MH levels, and received psychiatric and counseling care in multiple facilities.
- Lyle was transferred from Hartford Correctional Center to Garner for Mental Health 4 treatment housing and was monitored by fifteen-minute checks and video surveillance.
- Lyle died by hanging on May 21, 2008; the defense moved for summary judgment arguing no deliberate indifference and that immunity laws protect the defendants.
- The court grants summary judgment on all remaining counts, concluding no constitutional violation or wanton/malicious conduct shown.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference by medical staff | Gasparo/Sampson ignored acute suicide risk despite history | Care followed standard of care; no imminent risk | Granted summary judgment for Gasparo/Sampson on Counts I–II |
| Substantive due process violation by officers | Swan failed to prevent suicide; shows conscience-shocking conduct | Swan’s monitoring was consistent with guidelines | Granted summary judgment for Swan on Count III (Standish already conceded) |
| Wrongful death immunity under CT law | Defendants acted outside scope or with wanton conduct | Actions within scope; immunity applies unless wanton, reckless or malicious | Granted summary judgment for all on Count IV; immunity applies |
| Eighth vs. Fourteenth Amendment basis for detainee rights | Rights are substantial under due process due to pretrial detainee status | Standards align with Fourteenth Amendment due process; no difference in standard | Court analyzes under Fourteenth Amendment; no violation found |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires awareness of substantial risk and inference of harm)
- Estelle v. Gamble, 429 U.S. 97 (1976) (medical malpractice becomes a constitutional violation only with deliberate indifference)
- Caiozzo v. Koreman, 581 F.3d 63 (2d Cir. 2009) (standard for deliberate indifference under due process; subjective culpability)
- Cuoco v. Moritsugu, 222 F.3d 99 (2d Cir. 2000) (substantive due process in detainee context; governing standard)
- Weyant v. Okst, 101 F.3d 845 (2d Cir. 1996) (detainee rights; due process standard for care in custody)
- County of Sacramento v. Lewis, 523 U.S. 833 (1998) (requires conscience-shocking conduct for due process violation)
- Hathaway v. Coughlin, 37 F.3d 63 (2d Cir. 1994) (deliberate indifference standard uses subjective component)
- Martin v. Brady, 261 Conn. 372 (2002) (scope of employment; why actions outside scope may negate immunity)
- Rellegert v. Cape Girardeau County, 924 F.2d 794 (8th Cir. 1991) (liability when responding to risk; not just fault)