Miller v. Harbaugh

Federal 7th Circuit Court
Civil Court
Citation
Case Number: 
No. 11-3418
Decision Date: 
October 19, 2012
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed
Dist. Ct. did not err in granting defendants-prison officials’ motion for summary judgment after finding that defendants were entitled to qualified immunity in section 1983 action alleging that defendants were deliberately indifferent to decedent’s severe mental illness where decedent committed suicide by hanging himself from top of bunk bed in jail cell. While plaintiff asserted that defendants were deliberately indifferent by assigning decedent to cell with bunk bed under circumstances where bunk beds had been used before to assist inmates in committing suicide, Ct. found that defendants were entitled to qualified immunity where: (1) decedent did not present imminent risk of suicide at time of incident; and (2) law was unclear at time of incident that defendants had duty to adopt measures designed to thwart actions of inmates who were not actively or imminently suicidal.