Haney v. City of Cumming

Citations: 69 F.3d 1098; 1995 U.S. App. LEXIS 32861Docket: 19-13482

Court: Court of Appeals for the Eleventh Circuit; November 27, 1995; Federal Appellate Court

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The Eleventh Circuit Court of Appeals reviewed a case involving Brandon Joshua Haney and Dana Shaun Haney, who filed a lawsuit under 42 U.S.C. § 1983 following a prison suicide incident. The court addressed the district court's summary judgment ruling concerning claims of qualified immunity by police and sheriff's department officials. The court reversed the denial of summary judgment on those immunity claims and dismissed other issues due to lack of appellate jurisdiction.

The factual background details an incident on April 20, 1989, when Cumming police arrested Dana Shaun Haney and Jacqueline Hunt for theft of services at a local hotel. After being booked, Hunt ingested Xanax pills and subsequently collapsed at the Forsyth County jail, where Haney was placed in a detoxification cell. During an interview with Russell Matthews, a chief investigator, Haney expressed concern for Hunt's health. Following the interview, Haney exhibited alarming behavior, indicating suicidal thoughts by stating she "might as well kill" herself, after which she was returned to her cell. Despite her earlier comments, the officers failed to relay her suicidal indication to the city jail staff, resulting in her placement in an unsupervised cell.

A dispatcher at the city jail discovered Haney hanging in her cell with a sheet around her neck, and despite revival attempts, she was pronounced dead. Prior to this incident, neither the Forsyth County nor Cumming city jail had recorded a suicide. Following Haney's death, her mother, Margean Haney, acting on behalf of her minor son and as administratrix of Haney's estate, filed a lawsuit against the City of Cumming, Cumming Police Chief Wayne Lindsey, Forsyth County, Sheriff Wesley Walraven, Inspector Russell Matthews, and Officer Rusty Griffin. The district court initially compelled the Plaintiffs to respond to discovery requests, and upon their noncompliance, dismissed the complaint. This dismissal was later set aside after the Plaintiffs' counsel admitted to not informing them of the discovery order. After discovery concluded, the Defendants sought summary judgment. The court granted summary judgment for the City of Cumming and Chief Lindsey, ruling they had no special concern for Haney's condition upon her transfer. However, summary judgment was denied for Matthews and Griffin regarding qualified immunity, as the court found Haney's constitutional rights were clear at the time of her incarceration and factual questions remained about their actions. Forsyth County and Sheriff Walraven were granted summary judgment based on the constitutionality of Griffin's training and the inmate transfer policy, but the court denied it concerning Matthews' training and discretion. Additionally, summary judgment was granted for all Defendants on state law claims due to insufficient support from the Plaintiffs. The appeals stem from the district court's summary judgment rulings and the reinstatement of the Plaintiffs' complaint. Jurisdiction over these appeals is confirmed, particularly regarding the qualified immunity issue for Matthews and Griffin, as a trial court's denial at the summary judgment stage is immediately appealable. The jurisdiction over remaining claims is contested, but no party opposes the appellate jurisdiction.

Jurisdiction cannot be granted by the consent of parties; the court must independently assess its authority to hear a matter, regardless of any lack of objection from involved parties. An order that resolves fewer than all claims or parties does not terminate the action and is subject to modification before a final judgment is entered. According to Federal Rule of Civil Procedure 54(b), an order addressing some claims may be appealable only if certified by the district court; without such certification, the ruling remains interlocutory and not appealable under 28 U.S.C. § 1291.

The plaintiffs and Forsyth County Defendants contend that appellate jurisdiction exists over remaining claims as they are pendent to a qualified immunity appeal. Historically, the court has exercised discretion to take on additional issues linked to qualified immunity appeals, but this practice was rejected by the Supreme Court in Swint v. Chambers County Commission, which determined that such pendent appellate jurisdiction does not apply. Consequently, the court can only review the qualified immunity defense of Matthews and Griffin.

The plaintiffs allege that Matthews and Griffin's failure to prevent Haney's suicide violated her civil rights under the Eighth and Fourteenth Amendments. The district court denied their qualified immunity claim at summary judgment, and since qualified immunity involves legal questions, the court reviews this de novo. Although Swint suggests possible review for interwoven issues, the court finds no such connection exists in this case, thus limiting its review to Matthews' and Griffin's qualified immunity. Additionally, the court lacks jurisdiction to address the defendants' argument regarding the reinstatement of the plaintiff's complaint under Rule 60(b), as that order is also interlocutory and not reviewable without a final judgment.

To succeed in a prisoner suicide lawsuit, a plaintiff must demonstrate that a defendant exhibited deliberate indifference to the inmate's mental health and its potential consequences. The deliberate indifference standard is subjective, requiring proof that the defendant was aware of and disregarded a significant risk to the inmate's safety. Individual government officials performing discretionary functions may be protected by qualified immunity unless their actions violate clearly established rights that a reasonable person would recognize. If the plaintiff cannot show that the law was clearly established at the relevant time, qualified immunity applies.

In denying qualified immunity for Matthews and Griffin, the district court referenced Waldrop v. Evans, which indicated that officers could be liable for failing to address an inmate's psychological needs. However, in Belcher, it was clarified that Waldrop focused solely on physician liability and did not set a clear precedent for police officers. The responsibilities of Matthews and Griffin, as police officers, were not comparable to those of physicians, thus Waldrop did not establish relevant legal standards for their case. Case law prior to Haney's suicide in 1989 also failed to establish the applicable constitutional or statutory rights for police officers in similar situations. Consequently, the district court's decision to deny qualified immunity was incorrect, leading to a reversal of that denial. Other issues raised were dismissed due to lack of jurisdiction.