RESPONDENT: Karen Barkes, et al.
LOCATION: Howard R. Young Correctional Institution
DOCKET NO.: 14-939
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Third Circuit
CITATION: 575 US (2015)
DECIDED: Jun 01, 2015
GRANTED: Jun 01, 2015
Facts of the case
On November 13, 2004, Christopher Barkes was arrested for violating his probation. As part of his intake procedure, a nurse performed a medical evaluation, as required by the institution in which he was being held. Despite Barkes’ long history of mental health and substance abuse problems, neither his responses nor the nurse’s observations reached the threshold necessary under the institution’s protocols to initiate suicide prevention measures, so he was placed in a cell by himself. Barkes was awake and behaving normally at several points the following morning, but when an officer arrived to deliver lunch, Barkes had hanged himself with a sheet.
Barkes’ wife and children sued Stanley Taylor, Commissioner of the Delaware Department of Correction, and Raphael Williams, the warden of the institution in which Barkes had been held. The plaintiffs argued that the defendants had violated Barkes’ Eighth Amendment right to be free from cruel and unusual punishment by failing to properly supervise the contractor that provided medical treatment at the institution. The defendants moved for summary judgment based on the argument that they were entitled to qualified immunity because they did not violate a clearly established constitutional right, and the district court denied the motion. The U.S. Court of Appeals for the Third Circuit affirmed the denial of summary judgment.
Is there a clearly established constitutional right under the Eighth Amendment for an incarcerated person to have access to the proper implementation of adequate suicide prevention protocols?