Idaho Supreme Court Upholds Dismissal of Section 1983 Claims in Jail Suicide Case
The Idaho Supreme Court has affirmed a lower court’s dismissal of § 1983 claims stemming from the death of a detainee who committed suicide at the Ada County Jail (ACJ).
On September 28, 2008, Bradley Munroe was arrested for robbery. He was hospitalized because he was intoxicated, uncooperative and exhibiting odd behavior. Munroe claimed he would commit suicide if released, but the hospital cleared him and he was transported to ACJ.
During the booking process, Munroe was screaming, being rowdy and not making sense. Given his bizarre behavior, booking was suspended until the next morning and he was placed in a holding cell for observation.
James Johnson, a psychiatric social worker at the jail, assessed Munroe’s suicide risk. Johnson concluded that Munroe’s risk level was insufficient to justify admitting him to ACJ’s Health Services Unit (HSU).
After Johnson’s assessment, Munroe answered some suicide risk questions in the affirmative during the booking process. Guards did not contact staff in the HSU, however, based on Johnson’s evaluation.
Upon his request, Munroe was held in a single cell in protective custody. Guards were required to conduct well-being checks every 30 minutes.
At around 9 a.m. on September 29, 2008, Munroe’s mother, Rita Hoagland, called ACJ to express concerns that her son was suicidal. Hoagland’s concerns were reported to Johnson, but he did not alter his initial assessment.
That evening, Munroe was found hanging by a bed sheet from the top bunk in his cell. Efforts to revive him were unsuccessful.
On January 23, 2009, Hoagland filed suit in state court, in her personal capacity and as the representative of Munroe’s estate, claiming that guards were watching football when her son committed suicide. The initial complaint alleged § 1983 claims, state law torts and wrongful death claims.
When the defendants moved for summary judgment, Hoagland withdrew all of her state law claims and proceeded with only the § 1983 claims.
The trial court granted qualified immunity to Johnson and dismissed Hoagland’s claims against the other defendants. It awarded $15,815.31 to the defendants in costs as a matter of right and $77,438.12 in discretionary costs, but not attorneys’ fees.
On appeal, the Idaho Supreme Court found “the district court properly held that Munroe’s estate is not a valid § 1983 plaintiff,” because “Munroe’s § 1983 claim abated with his death.”
“This Court has clearly held that § 1983 is a personal cause of action. Furthermore, there is no federal law governing the issue of abatement. Therefore, the law of Idaho governs to the extent that it is not inconsistent with federal law. At common law in Idaho, a personal tort cause of action abates with the death of the plaintiff.”
The state Supreme Court also held that Hoagland had “failed to establish a violation of her constitutional rights underlying her § 1983 claim,” as she did not prove the defendants intentionally interfered with her relationship with Munroe.
Given Hoagland’s waiver of her state law wrongful death claim, the Court found that judicial estoppel barred her from asserting “that her § 1983 claim incorporates the wrongful death claim.”
The Supreme Court upheld the trial court’s denial of attorneys’ fees but reversed the discretionary award of costs to the defendants, noting that “the district court failed to make adequate findings.” On remand, the lower court was directed to reconsider the discretionary costs and make “express findings justifying the award.” The Court also reduced to $14,897.31 the costs awarded to the defendants as a matter of right. See: Hoagland v. Ada County, 154 Idaho 900, 303 P.3d 587 (Idaho 2013).