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A Lesson in Pleading: Utah Jail Suicide Complaint Fails for Alleging Failure to Train Rather than Failure to Provide Care
by David M. Reutter
On May 3, 2022, the U.S. Court of Appeals for the Tenth Circuit affirmed summary judgment for defendant jailers in a lawsuit seeking damages for a Utah detainee’s suicide. Not only bad for the survivors of the unfortunate man, the case also offers a …
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More from this issue:
- “I Was Scheduled to Die in Solitary Confinement” – and May Soon Be Again, by Mark Wilson
- From the Editor, by Paul Wright
- Detainees Awaiting Psychiatric Beds Suffer Permanent Harm in Jails, by Eike Blohm, MD
- Monterey County Sheriff’s Office Poised for Much-Needed Cleanup, by Kevin Bliss
- Federal Judge Tells BOP Officials They “Are Not Above the Law”, by Casey Bastian
- U.S. Response to Haitian Crisis: Fund More Prisons, by Jayson Hawkins
- California Halted from Re-Integrating “Sensitive Needs” Prisoners Into General Population, by David Reutter
- Circuit Court Orders Hawaii to Release Names of Prisoners Who Die in State’s Jails and Prisons, by Keith Sanders
- Former CoreCivic Guard Pleads Guilty to Deprivation of Tennessee Prisoner’s Rights, by Harold Hempstead
- $1.9 Million Paid by L.A. County for Detainee’s Suicide, by Chuck Sharman
- Sixth Circuit Revives Claim Over Michigan Prisoner’s Fatal Overdose on Allegedly Smuggled Fentanyl, by David Reutter
- Santa Clara County Sheriff Accused of Coverup After $10 Million Payout to Mentally Ill Detainee Who Severely Injured Himself During Jail Transport, by Benjamin Tschirhart
- Polling Stations Inside Jails Combat Voter Disenfranchisement, by Keith Sanders
- New Mexico Supreme Court Rules Both Prisoners and Nonprofit Plaintiffs Subject to Requirement to Exhaust Administrative Remedies, by Jacob Barrett
- Nevada DOC Director Sacked After Prisoner Escape Goes Unnoticed Four Days, by Ashleigh Dye
- Almost $650,000 Paid by Illinois to Prisoner Who Lost Leg to Untreated Diabetes, by Keith Sanders
- $11.75 Million Settlement for Prisoner Beating in Pheonix Jail, by Casey Bastian
- SCOTUS Ruling Forces Ninth Circuit U-Turn on Damages Suit by Federal Prisoner in California “Snitch Jacketed” by Guard, by Kevin Bliss
- BOP Revives Plans for Controversial Prison in Kentucky, by Kevin Bliss
- Second Circuit Takes Back $20,000 Emotional Damage Award from Former Federal Prisoner in New York, by Benjamin Tschirhart
- California Extends Medi-Cal Health Benefits to Prisoners Nearing Release, by Eike Blohm, MD
- Massachusetts Supreme Judicial Court: Jail Detainee’s Urine Not a ‘Noxious or Filthy Substance’, by David Reutter
- Iowa Ombudsman Calls Out DOC For Unfair Prisoner Discipline, by Kevin Bliss
- Virginia DOC Resists Prisoner Fee Cuts, by Ashleigh Dye
- Washington Racks Up More Than $98 Million in Fines for Failure to Timely Hold Competency Hearings, by Jacob Barrett
- Third Circuit Unbothered by Pennsylvania’s Discrimination Against Sex Offenders in Denying Parole to Halfway Houses, by David Reutter
- Indiana Will Now Send Low-Level Felons to Prison Instead of Jail, by Casey Bastian
- Fourth Circuit: Religious Headwear Policy Violated Virginia Prisoner’s Rights, by David Reutter
- A Lesson in Pleading: Utah Jail Suicide Complaint Fails for Alleging Failure to Train Rather than Failure to Provide Care, by David Reutter
- Sixth Circuit Says Ohio Prisoner’s Lack of Tablet Access May Have Prevented Grievance Exhaustion, by David Reutter
- Texas Prison Warden and Brother Charged with Shooting Two Migrants, Killing One, by Ashleigh Dye
- California Makes Calls Free for State Prisoners and Juvenile Detainees, Prohibits Telecom Kickbacks to Prisons and Jails, by Benjamin Tschirhart
- $35,000 Awarded to Federal Prisoner in Kentucky Who Accused Guards of Using Excessive Force, by Benjamin Tschirhart
- Educating Prisoners: New Meta-Analysis Reinforces That It Reduces Recidivism, by Keith Sanders
- $2.375 Million Settlement in Over-Detention Suit at Santa Clara California Jail, by David Reutter
- Montana Supreme Court Grants State Prisoner 604 Days in Sentence Credit, by David Reutter
- En Banc Ninth Circuit Voids Portion of California Law Banning Private Federal Prisons in the State, by Jacob Barrett
- Report Shows How Perverse Financial Incentives Drive Mass Incarceration and Inequity in Criminal Justice System, by Matthew Clarke
- Arizona Prisoner Waits in Excruciating Pain While Incompetent Executioners Fumble, by Eike Blohm, MD
- How the Newest Federal Prison Became One of the Deadliest, by Christie Thompson and Joseph Shapiro
- No More Second Chances for New York Jail Guard Convicted of Smuggling, by Benjamin Tschirhart
- “Ban the Box” Hiring Law Sets National Standard for Federal Contracts, by Keith Sanders
- No Pay for Iowa Prisoners Overdosed With COVID-19 Vaccine, by Benjamin Tschirhart
- Former State Prison Guards in Georgia Sentenced for Prisoner Assaults and Cover-Up, by Jayson Hawkins
- Suspended Colorado Work Release Program Exposes Companies’ Reliance on Low-Wage Labor, by Benjamin Tschirhart
- Seventh Circuit Revives Claim of Wheelchair-Bound Wisconsin Prisoner Denied Access to Handicapped Toilet, by David Reutter
- Seventh Circuit Overturns Class Decertification in Cook County Jail Disability Lawsuit, by David Reutter
- Despite Official Claims, Stopping Mail to Missouri Prisoners Has No Effect on Drug Overdoses, by Benjamin Tschirhart
- Former Georgia Sheriff Gets 18 Months for Punishing Detainees in Restraint Chair, by David Reutter
- $1.2 Million Paid by St. Louis County for Jail Detainee’s Death from Untreated Ulcer, by David Reutter
- Gun Safety Group Defeats Re-Election of “Constitutional Sheriff” in Massachusetts, by Keith Sanders
- Voters in Four States Change Constitution to Ban Prison Slavery, by Keith Sanders
- News in Brief
More from David Reutter:
- Sixth Circuit Announces State-Law Exceptions to Appeal Deadlines Preserve “Pending” Status Under AEDPA, Holding Belated-Appeal Procedures Toll Federal Habeas Limitations Period, April 1, 2026
- Florida Supreme Court Announces Rule 3.170(f)’s Good-Cause Plea-Withdrawal Standard Does Not Apply at Post-Appeal Resentencing, April 1, 2026
- Colorado Supreme Court Announces Defendant Must Be Competent Before Undergoing Mental-Condition Examination Under § 16-8-107(3)(b), April 1, 2026
- California Court of Appeal Announces Plea Agreements Cannot Bar § 1172.1 Resentencing, Holds Merit-Based Denial of Petition Is Appealable, April 1, 2026
- Georgia Supreme Court Clarifies That Failure to Object to Ineligible Juror Does Not Constitute Waiver Unless Party Knew or Could Have Discovered Ineligibility Through Ordinary Diligence, April 1, 2026
- Washington State Guard’s Conviction Affirmed in Self-Inflicted Gunshot Wound Scheme, March 1, 2026
- Massachusetts Supreme Judicial Court Holds Motion Judge Abused Discretion by Denying Evidentiary Hearing on IAC Claim Where Plea Counsel’s Affidavit Was Not Inherently Inconsistent With Colloquy Statements Regarding Immigration Advice, March 1, 2026
- Washington Supreme Court Clarifies Double Jeopardy Analysis for Multiple Assault Convictions, Holding That Assaultive Acts Occurring Over Short Time Period in Same Location Without Intervening Events Constitute Single Course of Conduct, March 1, 2026
- New Jersey Supreme Court Reverses Drug Convictions Under Cumulative Error Doctrine, Holding Combined Effect of Improper References to Television Series, Gun Violence, and Search Warrants Deprived Defendant of Fair Trial, March 1, 2026
- New York Court of Appeals Announces Coercive Police Tactics Compelling Suspect to Exit Home Constitute “Constructive Entry” Violating Payton, Holds Attenuation Analysis Applies to Third-Party Consent, March 1, 2026
More from these topics:
- New Jersey Lawmakers Pass “Female Incarcerated Person’s Rights Protection Act”, July 1, 2026. Staff-Prisoner Assault, Guard Misconduct, Prison Rape Elimination Act, Staff Training, Mothers in Prison.
- Three Women Died at a Michigan Prison in Less than a Month, July 1, 2026. Systemic Medical Neglect, Failure to Treat, Medical Neglect/Malpractice, Failure to Treat (Mental Illness), Deliberate Indifference.
- After Spoliation Sanction, CoreCivic Settles Suit Over Suicide in New Mexico ICE Lockup, July 1, 2026. Corrections Corporation of America/CoreCivic, Discovery, Medical Neglect/Malpractice, Failure to Treat (Mental Illness), Suicides.
- Tennessee Calls Off Execution After Botched Lethal Injection, July 1, 2026. Medical Misconduct, Pain, Staff Training, Cruel and Unusual Punishment, Lethal Injection Method of Execution.
- Study Shows That Suicide Intervention During and After Incarceration Reduces Suicide Attempts by 55%, June 1, 2026. Statistics/Trends, Suicides, Health care.
- Over $2 Million Paid by Otero County and VitalCore Health Strategies for New Mexico Jail Suicide, June 1, 2026. Failure to Treat, Medical Neglect/Malpractice, Suicides, Immunity - Sovereign/Municipal, Deliberate Indifference.
- Settlement Reached in Mental Health Care Class-Action at San Diego County Jails, June 1, 2026. Settlements, Failure to Treat (Mental Illness), Class Actions, Administrative Detention/Segregation, Inadequate Health Care Facilities.
- $1 Million Settlement Reached in Jail Suicide of Maryland Detainee Whose Emergency Hospitalization Order Was Ignored, June 1, 2026. Qualified Immunity, Failure to Protect (Wrongful Death), Suicides, 42 U.S. Code § 1983, civil action for deprivation of rights, Deliberate Indifference.
- Pepper Spraying Incident Prompts Policy Change at Washington Women’s Prison, June 1, 2026. Guard Misconduct, Pepper Spray/Tear Gas, Settlements, Staff Training, Cruel and Unusual Punishment.
- $250,000 Paid by Maine to Former Prisoner Held in Solitary Confinement—Which the State DOC Says Doesn’t Exist, June 1, 2026. DOC/BOP misconduct, Americans with Disabilities Act, Control Units/SHU/Solitary Confinement, Failure to Treat (Mental Illness), Cruel and Unusual Punishment.

