Pittman v. County of Madison, Ill.

Dist. Ct. erred in granting defendants-prison guards’ motion for summary judgment in section 1983 action alleging that defendants and other prison officials were deliberately indifferent to plaintiff-prisoner’s risk of suicide, and that they were willful and wanton by failing to provide adequate medical care to protect him from suicide attempt. Although Dist. Ct. found that defendants were not aware of plaintiff’s medical records or of any other sign that plaintiff posed substantial risk of suicide, Dist. Ct. could not make such findings since plaintiff presented evidence that defendants’ failure to act on plaintiff’s requests for mental health treatment in time span leading up to suicide constituted deliberate indifference, especially where defendants were also aware that plaintiff had displayed symptoms of depression prior to suicide attempt. Dist. Ct. did not err in granting summary judgment motion filed by prison medical personnel, where record lacked showing that said defendants had actual knowledge that plaintiff displayed risk of serious harm to himself, and that said defendants deliberately ignored said risk.