Eighth Circuit Revives Lawsuit Over Iowa Jail Detainee’s Suicide
by Matt Clarke
On January 6, 2026, the United States Court of Appeals for the Eighth Circuit reinstated a civil rights lawsuit brought by the parents of an Iowa jail detainee who committed suicide after reporting that he was in an acute mental health crisis with suicidal ideation.
In 2020, Jordan Kent Payne was booked into the Madison County Jail for contempt of court. His response to screening questions indicated he had a history of mental illness and suicide attempts. Two days later, he requested mental health services. Eyerly-Ball Community Mental Health Services had contracted with Madison County to provide jail diversion and intensive case management services at the jail. “These services generally included screening inmates for mental health needs and connecting inmates to mental health services providers,” according to court documents.
The next morning, Payne’s mother called the jail and reported that her son was “going nuts.” That afternoon, jail employee John Weakland brought Payne his medications and asked him if he was okay. Payne told Weakland that he needed to speak to a doctor, that he was “losing it in here,” and while he was generally “doing alright,” his “head [was] just not right.” Payne was not, however, placed on suicide watch or any kind of special monitoring plan.
Later that afternoon, Eyerly-Ball Jail Diversion Case Manager Scott Thomas spoke with Thomas. Payne told him that he had lost everything—including his housing, car, kids and girlfriend—and that he had already harmed himself by giving himself a black eye. He also said he was “hearing these fucking things in my head telling me all sorts of stupid shit,” including chewing his veins to commit suicide. Payne mentioned he had attempted suicide seven times in the past year.
Payne followed this by saying that he was not going to kill himself while in the jail but might after he was released. He told Thomas that he was not suicidal generally but that he kept having suicidal thoughts and did not want to go on suicide watch. Thomas promised to schedule Payne for an appointment with a psychiatrist.
After the meeting with Payne, Thomas told Weakland that Payne had said “he was not going to hurt himself in custody, but he was not sure what would happen when he left” but did not tell him about Payne’s previous suicide attempts or suicidal thoughts. About 10 minutes after returning from the interview with Thomas, Payne hanged himself. Weakland discovered his body about 90 minutes later.
Payne’s parents filed a federal civil rights action with pendent state claims. The district court dismissed everything except for a wrongful death claim against Thomas and a negligence claim against Eyerly-Ball.
Thomas and Eyerly-Ball filed a motion for summary judgment contending they were entitled to judgment as a matter of law because they owed no duty of care to Payne. The court agreed, holding that, under § 42 of the Third Restatement of Torts, because the interview with Thomas did not increase the risk of harm to Payne, no duty of care was owed him.
Aided by attorneys Corey F. Gourley, Robert G. Rehkemper, and Joseph Statler, the parents appealed.
The Eighth Circuit disagreed with the district court’s analysis, noting that, if Weakland was concerned about the possibility of Payne committing self-harm and Thomas passing on the redacted version of the interview reassured him, as seems to have happened, then Thomas’s actions did increase the risk of harm to Payne. The court noted that testimony from jail staff showed they relied on Thomas to assess and inform them about suicide risks. These disputed fact issues preclude summary judgment. Therefore, the judgment was reversed and the case remanded. See: Payne v. Eyerly-Ball Cmty. Mental Health Sevrs., 163 F.4th 1109 (8th Cir. 2026)
As a digital subscriber to Prison Legal News, you can access full text and downloads for this and other premium content.
Already a subscriber? Login
Related legal case
Payne v. Eyerly-Ball Cmty. Mental Health Sevrs.
| Year | 2026 |
|---|---|
| Cite | 163 F.4th 1109 (8th Cir. 2026) |
| Level | Court of Appeals |