Warren v. Yamhill County, 3:23-cv-00911

Shane Earl Rader, incarcerated at Yamhill County Jail, expressed suicidal intent and had a history of suicide attempts upon booking.
Rader was initially placed on suicide watch and evaluated by mental health professionals employed by the County, subsequently removed from suicide watch after he denied ongoing suicidal ideation.
Wellpath, contracted to provide medical (not mental health) care at the jail, attempted but failed to perform a physical screening due to Rader’s refusal.
Rader died by suicide in his cell; Wellpath staff were not found to have directly participated in his removal from suicide watch or in decisions about video monitoring.
Plaintiff, the personal representative of Rader’s estate, alleged Wellpath was deliberately indifferent, negligent, and grossly negligent, seeking liability under Monell and state law.
At the pleading stage, Wellpath moved to dismiss all claims, arguing the complaint failed to state claims connecting Wellpath’s conduct or policies to Rader’s harm.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Monell claim under § 1983 (policy or custom)	Wellpath’s policies/practices led to deliberate indifference to Rader’s serious medical needs	Complaint lacks factual link between Wellpath’s medical services/policies and Rader’s suicide	Dismissed—Complaint did not allege a Wellpath policy causing constitutional violation
Supervisory liability (§ 1983)	Wellpath RN Petrasek responsible for policies leading to harm as Health Services Administrator	No personal participation or sufficient connection to constitutional violation	Dismissed—No sufficient facts showing participation or direction by Wellpath supervisors
Negligence	Wellpath failed to meet the appropriate standard of medical care, causing Rader’s harm	Complaint does not identify how deficient medical care caused Rader’s suicide	Dismissed—No causal connection between medical care provided or not provided and harm alleged
Gross negligence	Wellpath’s conduct was reckless or indifferent to risk, leading to Rader’s suicide	No facts showing grossly negligent conduct caused Rader’s harm	Dismissed—Insufficient facts to support gross negligence tied to Wellpath’s medical role

Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipalities are only liable under § 1983 for deprivations caused by official policies or customs, not vicariously for employees)
Connick v. Thompson, 563 U.S. 51 (describes official municipal policy and deliberate indifference standards)
Shroyer v. New Cingular Wireless Servs., Inc., 622 F.3d 1035 (motion to dismiss standard—must state a plausible claim)
Wilson v. Hewlett-Packard Co., 668 F.3d 1136 (court must take well-pled factual allegations as true at the motion to dismiss stage)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard—conclusory statements insufficient, requires plausible factual support)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for federal pleading)
Taylor v. List, 880 F.2d 1040 (supervisory liability requires personal participation or actual knowledge and deliberate indifference)