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Summary Judgment Reversed in Illinois Jail Suicide Suit

The Seventh Circuit Court of Appeals reversed a lower court’s grant of summary judgment to Illinois jail officials stemming from the in-custody suicide of a federal pretrial detainee.

On April 13, 2005, Stanley Bell was confined at the St. Clair County Jail in Illinois. At the time he was admitted to the jail he was taking three prescription psychiatric medications.

During his regular weekly visit to the facility, contract psychiatrist Dr. Hetal Amin met with Bell on April 21, 2005 to conduct a psychiatric examination. “Bell, who suffers from bipolar affective disorder, became highly agitated and refused to talk with Dr. Amin in the presence of a jail officer, insisting that he was entitled to a private consultation with the doctor.” Jail policy required a guard to be present. “A standoff ensued, with Bell growing increasingly belligerent and refusing to participate in an examination until the jail officer left the room and Dr. Amin refusing to conduct the examination without the jail officer being present.”

Amin did not conduct the examination, “discontinued all of Bell’s medications and planned to try to examine him again the following week when he returned to the jail.” Two days later, on April 23, 2005, Bell committed suicide; he left a note “that said St. Clair County was responsible for his death because it had taken away his medication.”

Bell’s sister, Elisha Hunter, sued on her own behalf and as personal representative of Bell’s estate, alleging constitu-tional violations, medical malpractice and wrongful death. The U.S. District Court granted the defendants’ motion for summary judgment, and Hunter appealed.
On October 1, 2009, the Seventh Circuit affirmed the grant of summary judgment to St. Clair County, finding that Bell “did not have the right to an examination by Dr. Amin without the corrections officer remaining in the room.” Accordingly, the appellate court concluded that the county’s policy did not violate Bell’s constitutional rights, and thus there was no ba-sis for holding the county liable.

However, the Court of Appeals reversed the grant of summary judgment to Dr. Amin on the medical malpractice claim. While “Dr. Amin cannot be held liable for failing to conduct an examination of Bell,” the Court explained that Hunter “also alleges that Dr. Amin committed malpractice by discontinuing Bell’s medication ... Bell did not refuse to continue his medication, rather, he refused to submit to a psychiatric examination by Dr. Amin.” The Seventh Circuit found “no evi-dence to support Dr. Amin’s bare assertion that it was necessary for Bell to be examined by him in order for his previ-ously-prescribed medication to be continued.” See: Hunter v. Amin, 583 F.3d 486 (7th Cir. 2009).

The remaining medical malpractice claims against Dr. Amin settled on remand under undisclosed terms.

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Related legal case

Hunter v. Amin