Bays v. Montmorency County

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On April 9, Montmorency County jail nurse Sigler interviewed Shane, arrested for driving on a suspended license. Shane complained that he was “bipolar,” “paranoid,” had “panic attack[s]” and had a history of substance abuse. Sigler noted the need for a mental health evaluation and for a referral for “emergency treatment” “on discharge.” She returned Shane to the general population. Shane requested another meeting and described himself as anxious, paranoid, tense, unable to sleep, and experiencing “severe rage.” Sigler telephoned Pilarski, a nurse specializing in mental health. Pilarski recommended Benadryl and a follow-up appointment. Sigler scheduled Shane for a May 2 appointment. The center offered an earlier appointment, but a deputy would be on vacation at that time and transportation would be difficult. She recorded that Shane “denies suicide.” At an April 17 meeting, Sigler noted that he was less anxious. On April 19, he reported that he was afraid he would hurt others and that he had scraped his hands punching the wall. Hoping to schedule an earlier appointment, Sigler called Pilarski but could not reach her. Shane hanged himself in the shower on the night of April 22-23. In his parents’ action under 42 U.S.C. 1983, the court granted the county summary judgment. The Sixth Circuit affirmed denial of Sigler's claim of qualified immunity. A triable issue of fact remains over whether Sigler violated Shane’s clearly established Fourteenth Amendment right to sufficient treatment for a serious medical problem. View "Bays v. Montmorency County" on Justia Law