Whitney v. City of St. Louis

After being arrested, Whitney was taken to the St. Louis University Hospital for treatment of an irregular heartbeat. He attempted to escape and said that he wanted the police to take his life so that he would not be sent back to prison. He was determined to be suicidal. After being treated by psychiatry and showing improvement, he was released and transported to the St. Louis City Justice Center. Two days later, Whitney was moved to a medical unit, suffering from detoxification from heroin use, congestive heart failure, hypertension, and diabetes. Sharp was assigned to monitor Whitney in his cell via closed-circuit television. Sharp last saw Whitney pacing by the shower area at 9:05 a.m. Within the next 14 minutes, she discovered that he had hanged himself, using his ripped hospital gown. The district court dismissed 42 U.S.C. 1983 claims by Whitney’s estate. The Eighth Circuit affirmed. The complaint failed to allege that Sharp knew that Whitney presented a suicide risk. There was no claim that any identifiable jail official had knowledge or suspected that Whitney was suicidal or was harming himself; the complaint fails to allege any constitutional violation arising out of a municipal policy that would expose the city to Monell liability. View "Whitney v. City of St. Louis" on Justia Law