Seventh Circuit Dismisses Jail Detainee Suicide Case for Lack of Showing Deliberate Indifference
On July 29, 2025, the United States Court of Appeals for the Seventh Circuit upheld the dismissal of a case brought against a Wisconsin county jail relating to a detainee’s suicide, affirming the lower court’s ruling that the deceased’s family failed to meet the deliberate indifference standard for medical negligence cases.
Twenty-year-old Donna Christensen turned herself into tribal police on October 1, 2020, after violating the terms of her probation. She was then transferred to Vilas County Jail in the northern Wisconsin town of Eagle River. Donna had been in the jail previously in early 2020, and staff were aware of her drug abuse history, her anti-depressant prescription, and her previous attempts at suicide.
On intake, she tested positive for amphetamines, methamphetamines, and THC. She was denied treatment for her withdrawal symptoms by medical staff, despite being requested by a jail official. When she began running a temperature soon after admittance, she was given a COVID-19 test and moved to quarantine pending the outcome of the test.
After some time in a cell alone, Donna began to deteriorate. Officers accused her of “throwing a temper tantrum” when they didn’t provide her soap upon request. She proceeded to break her TV remote and cover her cell window with toilet paper. When officers entered her cell, she threw a Styrofoam tray containing food at one of them; they took her blanket and mattress pad in response.
Donna responded by threatening suicide, and was moved to suicide watch, though she spent an unspecified amount of time in a restraint chair before willingly changing into the suicide smock.
On October 7, Donna told Kayla Ziemba, a social worker at the jail from whom she had received counseling for three years outside the jail, that she was having thoughts of self-harm “all the time.” Ziemba recommended Donna stay on suicide watch, and Donna responded by calling Ziemba a “bitch.”
The following day, Ziemba returned, and Donna denied suffering from suicidal ideations, at which time Ziemba recommended she be removed from suicide watch. She was moved to 23-hour lockdown in D-Block to serve her disciplinary segregation for throwing food at a guard. At the time, only two other prisoners were on D-Block. However, from October 16th to the 26th, Donna was the only detainee housed there, and she had no contact with other detainees.
Around 8 p.m. on the 26th, Donna had a 20-minute video call with a friend, and one guard observed her crying afterwards. At 10:30 p.m., a guard discovered Donna hanging from the bunk by a sheet. Paramedics arrived at 10:41 p.m., but they could not revive her, and she was pronounced dead at the scene.
Her parents sued the jail staff and its mental health provider for various claims, but primarily that she shouldn’t have been released from suicide watch a day after expressing extreme suicidal ideation and while still suffering from untreated withdrawal symptoms in solitary confinement.
The district court determined there were no disagreements by the parties on any material issues of fact. It granted summary judgement for the defendants, ruling that “[t]he defendants may have made unwise decisions, such as releasing Donna from suicide watch without a more robust evaluation and then effectively isolating her.” However, this neglect did not rise to the level of deliberate indifference.
The Court of Appeals wrote that “[n]egligence or mistakes in medical judgement do not amount to deliberate indifference under the law, nor does evidence that a different medical professional would have chosen a different course of treatment,” citing Petties v. Carter, 836 F.3d 722 (7th Cir. 2016).
Upholding the district court’s judgment, the Court of Appeals similarly determined that, despite jail staff’s “failure to alleviate a significant risk” to Donna, their conduct did not amount to deliberate indifference. See: Christensen v. Weiss, No. 24-1026 (7th Cir. 2025).
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Related legal cases
Christensen v. Weiss
| Year | 2025 |
|---|---|
| Cite | No. 24-1026 (7th Cir. 2025) |
| Level | Court of Appeals |
Petties v. Carter
| Year | 2016 |
|---|---|
| Cite | 836 F.3d 722 (7th Cir. 2016) |
| Level | Court of Appeals |