Surya Nallani v. Wayne County
665 F. App'x 498
| 6th Cir. | 2016Background
- Srinivas Nallani, a pretrial detainee with a history of depression, ADHD, prior therapy, and prior suicidal thoughts, was booked into the Wayne County jail after an attempted firearm purchase while under federal indictment.
- Mental-health staff screened and evaluated Srinivas between May 31 and June 5, 2013; providers diagnosed adjustment disorder/ADHD, prescribed Zoloft and trazodone, and recommended follow-up but found no current suicidal ideation.
- Srinivas remained on the jail’s fourth-floor mental-health unit; jail protocol required an initial card-census check at shift start (3–5 minutes, wake inmates and verify identity) and quarter-hour/half-hour rounds thereafter, with special precautions for mentally ill inmates.
- On June 11, 2013, Corporal William Covington performed the 7:00 a.m. card census in 20 seconds, admitted he did not verify Srinivas’s face or wristband or rouse him; later that morning Srinivas was found dead with a plastic bag around his head, cause of death asphyxia.
- Plaintiff Surya Nallani sued under 42 U.S.C. § 1983 (deliberate indifference) against county, sheriff, medical staff, and deputies/corporal; the district court granted summary judgment for all defendants; the Sixth Circuit reversed as to Covington and affirmed as to the other defendants and the municipality.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether individual defendants were deliberately indifferent to a serious medical need (suicide risk) | Nallani: defendants ignored facts (depression, prior ideation, medication lapses, placement on mental-health unit, access to plastic bags) creating substantial risk | Defendants: they did not observe suicidal ideation; followed routine practices; some checks occurred and they reasonably believed inmates sleeping with blankets were normal | Court: Objective prong satisfied; most individual defendants entitled to summary judgment except Covington — genuine dispute as to his subjective deliberate indifference |
| Whether medical provider (Dr. Zuhairy) was deliberately indifferent (medical care) | Nallani: Zuhairy failed to recognize/treat a clear suicide risk, prescribed inadequate care | Zuhairy: evaluated patient, found no current suicidal ideation, prescribed meds and recommended follow-up; errors at most amount to malpractice, not constitutional violation | Court: Summary judgment for Zuhairy affirmed — evidence, at most, shows negligence, not deliberate indifference |
| Whether Corporal Covington is entitled to qualified immunity | Covington: no clearly established right violated or he reasonably performed duties | Nallani: Covington’s cursory 20‑second census showed conscious disregard of known risks on mental-health ward | Court: Qualified immunity denied as to Covington — deliberate indifference to serious risk was clearly established (Estelle/Farmer) |
| Whether Wayne County / Sheriff liable for failure to train/supervise (Monell) | Nallani: county training/supervision inadequate and caused the violation | County: deputies had suicide-awareness training and manuals; plaintiff fails to show deliberate indifference or causation | Court: Summary judgment for county and official-capacity sheriff affirmed — no evidence of deliberate indifference in training causally tied to death |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to serious medical needs violates the Constitution; malpractice alone is insufficient)
- Farmer v. Brennan, 511 U.S. 825 (1994) (prison officials liable only if they know of and disregard substantial risk to inmate safety)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity two-step inquiry)
- Ingraham v. Wright, 430 U.S. 651 (1977) (pretrial detainees’ protection analyzed under Due Process but Farmer analysis applies)
- Comstock v. McCrary, 273 F.3d 693 (6th Cir. 2001) (deliberate indifference standard applied to psychiatric/suicide-risk claims)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability requires unconstitutional policy or custom)
- City of Canton v. Harris, 489 U.S. 378 (1989) (failure-to-train municipal liability framework)
- Barber v. City of Salem, 953 F.2d 232 (6th Cir. 1992) (proper inquiry for liability for detainee suicide)
- Horn v. Madison Cty. Fiscal Court, 22 F.3d 653 (6th Cir. 1994) (psychological needs may be serious medical needs)