Taylor v. Barkes

There is no clearly established Eighth Amendment right to adequate suicide prevention methods therefore, qualified immunity is proper.

Petitioners, a prison administrator and the Commissioner of the Delaware Department of Corrections were sued under 42 U.S.C. §1983 for the death of an inmate. As part of the intake process, each inmate is given a suicide check. The victim allegedly had a history of substance abuse and mental health issues, but he passed the suicide check and was placed in his own cell. The deceased called his wife, one of the Respondents, and told her he was contemplating suicide. Respondent did not notify anyone at the prison. Correction Officers found the victim hanging by his bed sheets inside his cell.

The Respondents claimed the Petitioners failed to protect the victim from cruel and unusual punishment by failing to monitor the independent contractor administering the suicide. The District Court denied Petitioners motion for qualified immunity. The Third Circuit affirmed and found there was a breach of supervisory duty and there was a clearly established right to adequate suicide prevention measures under the Eighth Amendment.

The U.S. Supreme Court reversed the decision and found Petitioners were unaware of a clearly established right. There is no Supreme Court decision stating there is right to suicide prevention. Colburn I states that the prison cannot act recklessly when there is an inmate contemplating suicide. Colburn II found that there did not need to be a formal intervention system in place. As a result, Petitioners could not know they were in violation of a constitutional right. Therefore, the right is not clearly established.