Cagle v. Sutherland.

• Position: Prisoner suicide case

U.S. Appeals Court

SUICIDE

SUPERVISION

Cagle v. Sutherland, 334 F.3d 980 (11th Cir. 2003). The personal representative of the estate of a pretrial detainee who hung himself in his cell brought a [section] 1983 action, alleging that officials failed to prevent his suicide. The district court denied summary judgment in favor of the defendants and they appealed. The appeals court vacated and remanded. The appeals court held that the county's violation of a consent decree that arose out of a voluntary settlement of a prior jail conditions lawsuit, did not establish a violation of the pretrial detainee's constitutional rights actionable under [section] 1983. The consent decree required the county to provide a second nighttime jailer to staff the jail during the hours that the detainee committed suicide, but the court noted that the prior lawsuit was not concerned with the risk of prisoner suicides. According to the court, the county's failure to fund the second jailer did not rise to the level of deliberate indifference to the...