Blakeslee v. Clinton County

Citation: 336 F. App'x 248Docket: No. 08-4313

Court: Court of Appeals for the Third Circuit; July 14, 2009; Federal Appellate Court

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Stacie Blakeslee, as Executrix of Robert Young's estate, filed a 42 U.S.C. § 1983 claim against officials at the Clinton County Correctional Facility (CCCF) after Young's suicide during a suicide watch. The District Court dismissed five unnamed John Doe defendants and granted summary judgment for the remaining defendants. Blakeslee appealed both decisions, which were upheld. Young, transferred to CCCF on July 11, 2005, attempted suicide a month later and was placed on a 15-minute alert watch in a restraint chair for safety. After requesting to lie down, he was moved to a cell with bunk beds, as specialized cells for suicide watch were occupied. Although guards monitored him as required, he hanged himself five hours later and died the following day.

The District Court dismissed the John Doe defendants under Federal Rule of Civil Procedure 21, which allows for the dropping of parties if their identities remain undiscovered after reasonable discovery efforts. Blakeslee had ten months for discovery, during which she took extensive depositions, but failed to identify the Doe defendants. The appellate court affirmed the dismissal, finding no abuse of discretion in the District Court's decision.

Plenary review applies to the District Court's grant of summary judgment, which is appropriate when there are no genuine issues of material fact, and the movant is entitled to judgment as a matter of law. Any contested facts are resolved in favor of the nonmoving party, and the appellate court can affirm or vacate based on any record-supported ground. Blakeslee contends that Clinton County is liable under 1983 due to inadequate training at its Correctional Facility regarding inmate suicide prevention. Municipal liability can arise from a policy or custom that violates constitutional rights or serves as a "moving force" behind an employee's constitutional tort. A municipality's failure to train can be actionable under 1983 only if it demonstrates "deliberate indifference" to the rights of its inhabitants. In cases of prison suicides, the plaintiff must prove that the training deficiency caused the guards' indifference to the inmate's medical needs. Viewing the evidence favorably for Blakeslee, she fails to show that the training at the Correctional Facility was deliberately indifferent. Actions such as placing Young in a cell with bunk beds and a blanket do not indicate a material fact dispute regarding municipal liability. Moreover, a guard's mistake does not imply inadequate training or supervision necessary to support a 1983 claim. Adequately trained officers can make errors, which do not reflect on the training program's adequacy. Blakeslee has not demonstrated a causal link between CCCF's training and Young's suicide attempt and death. To succeed on a failure to train claim, the training deficiency must be closely connected to the constitutional injury, and Blakeslee has not proven such a connection.

Blakeslee named four individual employees of CCCF as defendants, presumed to be municipal policymakers responsible for the allegedly unconstitutional policies and training at CCCF. However, since these policies and training were determined not to be unconstitutional, the individual defendants are entitled to summary judgment, mirroring the outcome for Clinton County. The court affirmed the District Court's decision, asserting jurisdiction under 28 U.S.C. 1291. Blakeslee's expert report indicated a lack of evidence showing the officers' indifference to care and safety, and confirmed that staff training adhered to state law and ACA standards. The District Court’s summary judgment included a thorough analysis of CCCF policies and training. Furthermore, if Blakeslee aimed to assert any alternative theory of individual liability, her claims fail as she did not demonstrate any personal involvement of these defendants in Young's suicide, as required for individual government defendants in civil rights actions.