Earl v. Racine County Jail

Dist. Ct. did not err in granting defendants-jail officials’ motion for summary judgment in section 1983 action alleging that defendants denied plaintiff-prisoner due process by failing to provide him with notice or hearing prior to placing him on suicide watch and failing to properly address his allergic reaction to wearing special gown given to prisoners on suicide watch. Record showed that plaintiff's placement on suicide watch over period of five days was too short of time frame to trigger due process protection, and that, although plaintiff faced more restrictions than those in general prison population, said restrictions, which pertained to type of eating utensils and type of blanket, were not overly harsh. Moreover, defendant-officer’s prompt call nurse to check out plaintiff’s alleged rash precluded any liability on plaintiff’s deliberate indifference claim, and defendant could otherwise rely on nurse’s diagnosis that she did not observe any rash that would require different garment.