Background
Earnestine Saxton Washington appealed the dismissal of her complaint on behalf of her son Antonio Saxton, who died while in custody at the Bossier City Jail. She alleged violations of the Eighth and Fourteenth Amendments, as well as state law claims for wrongful death and negligence.
The court’s reasoning
The court noted that the plaintiff abandoned challenges to Eighth Amendment and civil conspiracy claims. Regarding the Fourteenth Amendment due process claim, the court found she failed to allege that officials acted with subjective deliberate indifference. Specifically, there were no allegations that the deceased had a history of suicidal ideation or mental illness that would have put officials on notice of a substantial risk. The court reiterated that there is no independent constitutional right to suicide screening. Without allegations that authorities knew of a suicide risk, the dismissal was appropriate. The court also found the plaintiff failed to state a claim for wrongful death, survival, and negligence under Louisiana law. Finally, the court declined to address the Monell claim and affirmed that further amendment would be futile.
What it means going forward
The ruling reinforces the high pleading standard required to establish a due process violation in suicide cases within the Fifth Circuit, requiring specific allegations of official knowledge of risk.