Pulera v. Sarzant

Dist. Ct. did not err in granting defendants-prison officials’ motion for summary judgment in plaintiff-arrestee’s section 1983 action alleging that defendants failed to properly respond to signs that he was at risk for suicide, and that said failure resulted in plaintiff sustaining personal injuries when he attempted to commit suicide in his jail cell. Under Fourth Amendment’s objective reasonableness test applicable to arrestees who had not yet had probable cause hearing, Dist. Ct. could properly find that prison doctor’s withholding of plaintiff’s depression medication was reasonable given possibility that plaintiff had recently overdosed on said medication, and testimony otherwise indicated that there was no linkage between withholding of said medication and plaintiff’s suicide attempt. Also, Dist. Ct. could properly grant summary judgment in favor of non-medical defendants, where record showed that: (1) as to some defendants, there was no evidence that said defendants overlooked signs of plaintiff’s intent to harm himself; (2) some defendants could defer to medical personnel when assessing plaintiff’s complaints of physical discomfort; and (3) call to jail by plaintiff’s brother indicating that plaintiff was suicidal could properly have been ignored, where recent observation of plaintiff indicated that plaintiff did not act distraught and had not reported any suicidal thoughts. Fact that plaintiff had reported that he was taking depression medication did not require different result.