Estate of Sisk v. Manzanares.

• Position: FAILURE TO PROTECT - Deliberate indifference to the prisoner's medical needs, violation of civil rights - Brief Article

U.S. District Court

PRISONER SUICIDE

Estate of Sisk v. Manzanares, 262 F.Supp.2d 1162 (D.Kan. 2002). The estate and survivors of a deceased prisoner brought a civil rights action against a county corrections department, alleging deliberate indifference to the prisoner's medical needs. The district court held that summary judgment was precluded by a fact issue as to whether corrections officers were deliberately indifferent to the substantial risk that the inmate would commit suicide. The court held that the corrections officers were not entitled to qualified immunity because they had a clearly established affirmative duty under the Eight Amendment at the time of the prisoner's suicide, to take reasonable measures to abate a known risk that the prisoner was suicidal. The court held that a supervisor was not deliberately indifferent, noting that the mere fact that a supervisor was not integrally involved with the day to day activities of his subordinates did not mean that he was deliberately indifferent to the need to provide adequate medical care to a suicidal inmate, even though the supervisor was subjectively...