Ginger Headley; Mark Coffelt v. Centurion of Missouri, LLC; Amanda Lake

Holding: The Eighth Circuit reversed the denial of the motions to dismiss, holding that the correctional officers were entitled to official and qualified immunity.
Standard: Official immunity and qualified immunity standards
Vote: Panel Decision
Practical effect: The reversal shields correctional officers from civil liability in similar cases where the complaint does not clearly establish that officers had actual knowledge of a specific suicide risk or that their duties were purely ministerial without discretion.

The Eighth Circuit reversed a district court ruling that allowed a wrongful death and civil rights claim to proceed against correctional officers. The appellate court held that the officers were protected by official and qualified immunity because their duties involved discretion and the complaint failed to plausibly allege deliberate indifference.

Background

Corey Coffelt died by suicide while in administrative segregation at Missouri’s Moberly Correctional Center. His parents sued the correctional officers for wrongful death and under Section nineteen eighty-three of the United States Code, alleging the officers failed to provide adequate medical treatment and monitoring despite Coffelt’s known mental health issues and history of suicide attempts.

The court’s reasoning

The court analyzed the claim under Missouri law for official immunity, determining that the cell check policy did not create a ministerial duty because officers retained discretion in how to conduct the checks. Regarding the Section nineteen eighty-three claim, the court found the complaint failed to plausibly allege that the officers had actual knowledge of a substantial risk of suicide, noting contradictory allegations that officers both knew and did not review Coffelt’s prior records. The court further found the complaint did not adequately allege deliberate indifference to the risk.

Official immunity does not apply when a public officer fails to perform a ministerial duty required of him by law.

Morales, 679 S.W.3d at 471

What it means going forward

The reversal shields correctional officers from civil liability in similar cases where the complaint does not clearly establish that officers had actual knowledge of a specific suicide risk or that their duties were purely ministerial without discretion.