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Chicago Jail Not Liable for Suicide Despite Cell Design

The decedent hanged himself in a police lockup. All the relevant procedures (thorough screening, training of personnel, checking of cells every 15 minutes, removal of obviously dangerous object) were followed.

The existence of horizontal bars (from one of which the decedent hanged himself with his jacket) does not constitute deliberate indifference in light of the many precautions taken by the city to prevent suicide. At 782: "Another factor which is instructive, but not conclusive, of the issue in this case is that the type of cell used in Chicago detention facilities is authorized by the State of Illinois Municipal Jail and Lockup Standards for new construction." Plaintiff presents no evidence that the cells or the standards "fall outside the range of professional judgment about cell design." (782)

The plaintiffs argued that 20 suicides and 163 attempts over seven years showed deliberate indifference; the defendants argued that this amounted only to .0087 percent of arrests. At 782: "We do not think that numbers can tell the whole story. It is possible that one or two suicides coupled with other evidence could add up to deliberate indifference in a proper case." A larger number of suicides in light of other precautions might not constitute deliberate indifference. See: Frake v. City of Chicago, 210 F.3d 779 (7th Cir. 2000).

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Related legal case

Frake v. City of Chicago