Lapre v. City of Chicago

Dist. Ct. did not err in granting defendant-City’s motion for summary judgment in plaintiff’s section 1983 action alleging that defendant’s policies and practices concerning supervision of detainees in its lockup caused plaintiff’s death from suicide in his holding cell. Record showed that defendant’s personnel conducted screening questionnaire when plaintiff first arrived at jail, that plaintiff did not exhibit any behavior indicating suicide risk at that time, and that someone at jail visually inspected plaintiff in his cell every 15 minutes either in person or on video monitor until plaintiff was observed hanging himself in his cell. While plaintiff’s estate asserted that five of defendant’s policies demonstrated that it was deliberately indifferent towards risks of suicide and were moving force behind plaintiff’s death, plaintiff’s estate failed to support said claim with reliable statistics indicating that suicide rates at jail increased because of said policies or that suicide rate at defendant’s jail was disproportionate to suicide rate of free population. Also, plaintiff failed to show that defendant’s policies/practices of using horizontal bars in plaintiff's cell, failure to provide suicide kits to lockup personnel, failure to reassess suicide risks when detainees return from court appearances, failure to have personnel personally inspect detainees or failure to properly train personnel on identifying persons with suicide risks either had causative effect on plaintiff’s suicide or would affect frequency of suicides occurring at jail.