Lynas v. Stang

Background

James C. Lynas was arrested for driving under the influence and taken to Sherburne County Jail on November 1, 2017. He had reported drug use, withdrawal symptoms, depression, anxiety, and thoughts of self-harm. On November 5, he scored 43 on the Beck Depression Inventory, a standard depression-screening tool; scores above 28 indicated severe depression. He also reported thoughts of killing himself, although he said he would not act on them.

After consulting an on-call medical provider, nurse Alyssa Pfeifer placed Lynas on a 15-minute mental-health watch, restricted his access to razors, obtained anxiety medication, and made an urgent mental-health referral. The referral resulted in an appointment scheduled for November 16, but the opinion states that Lynas had no contact with a mental-health professional before his death.

On November 8, Lynas was moved to segregated housing, where inmates were confined to their cells for 23 hours each day. The opinion states there was no evidence that medical staff were notified of the move, even though jail policy required immediate notification. On November 9, correctional officers Michael Wise and Linda Stang conducted checks through small, obstructed catwalk windows. Lynas hanged himself with a sheet between checks. Wise saw part of Lynas’s head but did not enter the dayroom or otherwise verify that Lynas was alive and breathing. Stang initially saw only the top of his head and did not confirm that he was breathing. She discovered him during a later check.

Claims and Summary-Judgment Standard

David W. Lynas, as trustee for the next of kin of James C. Lynas, asserted claims under the Eighth and Fourteenth Amendments. The defendants moved for summary judgment under Federal Rule of Civil Procedure 56. Summary judgment is appropriate when there is no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment as a matter of law. The court viewed disputed facts and reasonable inferences in the plaintiff’s favor.

The relevant Eighth Amendment theory was deliberate indifference to a serious medical need. The plaintiff had to show an objectively serious medical need, that the defendant actually knew about it, and that the defendant deliberately disregarded it. The court treated suicide risk as a serious medical need. It described deliberate indifference as conduct equivalent to criminal-law recklessness: more blameworthy than negligence but less than intentionally causing the harm.

Correctional Officers Stang and Wise

The court denied the Sherburne County Defendants’ motion for summary judgment. It held that the evidence could support a finding that Lynas had an objectively serious medical need because he had expressed suicidal thoughts, had a severe-depression score, and had been placed on a 15-minute mental-health watch after an urgent referral.

The court also found a genuine factual dispute about whether Stang and Wise actually knew of Lynas’s suicide risk. They knew that he was on the jail’s highest-level 15-minute mental-health watch and that he could not have a razor. The court concluded that a reasonable factfinder could determine that these facts communicated a suicide risk, even though the defendants argued that they did not know the underlying reasons for the watch.

The court further found a factual dispute about deliberate indifference. Wise and Stang knew that the purpose of the checks was to confirm that an inmate was alive and breathing. Yet, viewing the evidence in Lynas’s favor, their checks confirmed only that his body was present and did not adequately determine whether he was alive. Because a reasonable factfinder could find both a constitutional violation and violation of a clearly established right, the court denied the officers’ qualified-immunity argument at summary judgment.

MEnD Individual Defendants

The court granted summary judgment to Pfeifer and Thompson. Thompson learned that Lynas had considered self-harm, completed a suicide-risk screening, noted that his score was below MEnD’s intervention threshold, and offered him the opportunity to begin MEnD’s mental-health process. The court concluded that she acted reasonably and that no genuine factual dispute remained about deliberate indifference.

Pfeifer learned of Lynas’s high depression score and suicidal thoughts, contacted the on-call medical provider, reported additional information, placed him on a 15-minute mental-health watch, restricted razors, arranged anxiety medication, and submitted a mental-health referral. The court concluded that no genuine factual dispute remained about her deliberate indifference.

The court denied summary judgment to Robertson. Although he knew the information collected by the nurses, he did not interview Lynas or provide care before the scheduled November 16 appointment. The court held that a reasonable jury could find that Robertson refused to provide essential care by scheduling the appointment too far in the future for an inmate in crisis.

The court granted summary judgment to Leonard on the claim based on his personal conduct and on the supervisor-liability claim. Leonard reviewed information collected by the nurses but did not personally meet with Lynas. The court found that Lynas had not shown that Leonard’s inaction reached the required level of deliberate indifference or that Leonard knew about Robertson’s scheduling decision.

MEnD’s Entity Liability

The court denied summary judgment to MEnD Correctional Care, PLLC. Under the rule commonly called Monell liability, an entity performing a governmental function may be liable when a policy or custom causes a constitutional violation and reflects deliberate indifference to known or obvious consequences.

The court found a genuine factual dispute about whether MEnD’s alleged understaffing, limited physician oversight, and use of proprietary suicide-screening forms with unexplained scoring thresholds amounted to a deliberately indifferent policy or custom. A reasonable jury could find that these practices affected the medical care Lynas received and contributed to a constitutional violation.

Sherburne County’s Entity Liability

The court denied summary judgment to Sherburne County. It found factual disputes about whether the jail prohibited use of the term “suicide watch” and instead grouped potentially suicidal inmates with other inmates on a “mental-health watch.” A reasonable jury could find that this practice made suicide risk harder to identify.

The court also found a factual dispute about the jail’s policy allowing catwalk checks despite their limited visibility, including for at-risk inmates. The court did not find sufficient evidence that the County had a policy of conducting checks too quickly, that failing to follow written policies itself constituted a continuing custom, or that the County knew about MEnD’s specific staffing and screening-form problems.

Order

The court ordered that the Sherburne County Defendants’ motion for summary judgment was DENIED. It ordered that the MEnD Defendants’ motion was GRANTED in part and DENIED in part. The motion was granted as to claims against Pfeifer and Thompson in their individual capacities and Leonard in his official and individual capacities; those claims were dismissed with prejudice. The motion was denied as to Robertson and MEnD Correctional Care, PLLC.