Logue v. United States

• Jurisdiction: United States

Logue v. United States

412 U.S. 521 (1973)

Facts

Reagan Logue was arrested by U.S. DeputyMarshalDelBowersinMay1968 for smuggling 229 pounds of marijuana into the United States. After his first hearing, he was taken to a local jail, the Nueces County Jail in Corpus Christi, Texas, to await trial. The Nueces County Jail was one of 800 state and local institutions that contracted with the Federal Bureau of Prisons for the safekeeping of prisoners. One day after his incarceration at the Nueces County Jail, Logue attempted suicide by slashing the veins in his left arm. The wound turned out to be minor, but he was admitted to the hospital's psychiatric unit because the attending doctor found him to be hallucinating and out of touch with reality. A psychiatrist recommended that Logue be admitted to a medical facility for rehabilitation. He was transferred back to the Nueces County Jail to await a transfer to a federal medical facility. On the transfer, Deputy Marshal Del Bowers informed the chief local jailer of Logue's suicidal tendencies and gave instructions to prepare a special cell removed of all dangerous objects for him. Jail authorities prepared the special cell for Logue, but because Bowers gave no instructions to provide constant surveillance, jail officials did not place Logue under constant surveillance, only periodically checking on him. One day after returning to the jail, Logue removed a gauze bandage that had been applied to his laceration and hanged himself. His parents sued the U.S. government for damages under the Federal Tort Claims Act for negligence and being the proximate cause of their son's death. The U.S. District Court for the Southern District of Texas found that (1) the local jail authorities were negligent in providing inadequate surveillance of the prisoner; (2) Bowers was negligent for failing to make specific arrangements for the constant surveillance of Logue; and (3) the U.S. government was liable for the negligent acts of both the deputy marshal and the Nueces County Jail employees. The Court of Appeals for the Fifth Circuit reversed the District Court's decision, holding that under the "contractor clause" the county jail fell within exclusion from the Federal Tort Claims Act. Hence, the local jail authorities were not acting as agents of the U.S. government, and because the Deputy Marshal had no power over any jail employee or control of the inner functions at the jail, he violated no duty of safekeeping in regard to the...