Estate of Rice v. Correctional Medical Services

In section 1983 action alleging that defendants (jail officials and medical personnel) had deprived plaintiff-deceased prisoner's due process rights by exhibiting deliberate indifference to plaintiff's declining schizophrenia and physical conditions that led to plaintiff's death from excessive water drinking, Dist. Ct. erred in granting defendants-jail officials' motion for summary judgment with respect to claim that said defendants subjected plaintiff to unsanitary conditions of his confinement where record contained evidence that said defendants, with knowledge of plaintiff's mental condition, allowed plaintiff to be confined in unsanitary cell and to remain un-bathed and incapable of caring for himself. However, Dist. Ct. did not err in granting all defendants' motion for summary judgment with respect to claim that defendants' alleged deliberate indifference resulted in plaintiff's death where, even though defendants were aware of plaintiff's mental condition, as well as negative ramifications of his seclusion, lack of self-care and weight loss, defendants had no warning that plaintiff might experience psychogenic polydipsia that led to his death from water intoxication. Fact that plaintiff was involved in prior incident when he cut his throat with razor did not require different result where plaintiff ultimately did not commit suicide. Ct. erred, though, in subsequently dismissing plaintiff's state wrongful death action on grounds of collateral estoppel since prior Dist. Ct. finding in section 1983 action that plaintiff's death was not foreseeable was not necessary finding in resolution of section 1983 action so as to support application of collateral estoppel.