Seventh Circuit Reverses Dismissal of Case Challenging Conditions in Illinois Jail
where Mentally Ill Prisoner Died

On March 20, 2012, the Seventh Circuit Court of Appeals reversed a district court’s grant of summary judgment to the defendants in a case claiming inhumane conditions of confinement at a county jail; the appellate court also reversed the dismissal on collateral estoppel grounds of a related suit raising state law claims.

The case involved two lawsuits filed by the estate of Nicholas D. Rice, 21, who died in the Elkhart County, Illinois jail on December 18, 2004, nearly fifteen months after he was booked into the facility pending trial on a charge of attempted bank robbery. Rice suffered from schizophrenia, and 11 days before his death was found incompetent to stand trial and ordered admitted to a psychiatric hospital.

The conditions at the jail and the treatment (or lack thereof) that Rice received are extensively detailed in the lengthy appellate opinion in this case. In sum, the record indicated that although Rice was seen by mental health staff while incarcerated, he “frequently refused to take his prescribed medications, cooperate with medical personnel at the jail, eat his meals, or bathe himself.” Medical care at the jail was provided by Correctional Medical Services (CMS), a private company now known as Corizon.

In an April 30, 2004 note, jail staff wrote “that Rice was unable to stand, that his entire body was jaundiced, that he had a large, three-inch area of dark skin over his coccyx, and that when officers picked him up, dead skin cells sloughed off his body in large numbers. He refused to speak.”

Rice was briefly hospitalized at psychiatric and other medical facilities on several occasions during the period of his confinement. He died in an administrative segregation cell at the jail as a result of psychogenic polydipsia (excessive water drinking), which is a disorder known to manifest in some people afflicted with schizophrenia.

The district court granted the defendants’ motion for summary judgment, finding that they had not consciously disregarded Rice’s medical needs and that the ultimate cause of his death was not a foreseeable outcome. Rice’s estate then filed a second federal lawsuit that included state law claims against CMS which had been dismissed without prejudice in the first case, invoking the district court’s diversity jurisdiction. The court, with a different judge, dismissed the suit based on collateral estoppel due to the determination in the first lawsuit that the cause of Rice’s death “was not reasonably foreseeable to the defendants.”

Of the two causes of action that the Seventh Circuit found merited reversal, the first contended that jail officials and staff were deliberately indifferent to the inhumane conditions in which Rice was held at the jail. The Court of Appeals concluded that such conditions presented a disputed material fact that must be resolved at trial.

Although Rice himself had created the unsanitary conditions, that did not foreclose the claim because prison officials have an obligation to intervene when they know a prisoner suffers from self-destructive behavior. While the record indicated that staff had showered Rice and cleaned his cell on multiple occasions, it also showed that “his cell was often filthy and unsanitary, that uneaten food was left to rot there, that his skin was sometimes caked with his own feces, that he had an extremely foul body odor owing to the long periods of time during which he went unbathed, and that he either developed or was on the verge of developing bed sores on multiple occasions....”

The appellate court held a jury could find the defendants should have made a more conscientious effort to bathe Rice and clean his cell, noting “there were significant periods of time during which the jail’s staff members simply turned their back on the condition of Rice’s person and cell, knowing that he was living in his own filth.” The jury could also conclude those conditions exceeded mere discomfort and were constitutionally unacceptable.

“We conclude, contrary to the district court, that whether jail officials were deliberately indifferent to Rice’s conditions of confinement presents a material dispute of fact that the factfinder must resolve at trial,” the Court of Appeals wrote. “That Rice himself created the unsanitary conditions of which his Estate complains certainly is a fact relevant to this claim.... But given Rice’s mental condition, it by no means forecloses the claim, as the district court appears to have assumed.”

The appellate court affirmed the dismissal of other claims raised by Rice’s estate, including claims related to his placement in administrative segregation, excessive force and failure to protect.

In addition to reversing the dismissal of the conditions of confinement claim, the Seventh Circuit found the dismissal of the state law claims raised by Rice’s estate in the second lawsuit was in error. That dismissal was based on the district court’s finding that the cause of Rice’s death was not foreseeable in determining whether the defendants were deliberately indifferent to his medical needs. As the foreseeability issue was not necessary to determine deliberate indifference – which required different standards than those applied to state law negligence claims – the Court of Appeals held that the foreseeability determination in the first case did not provide preclusive effect to dismiss the state law claims raised in the second lawsuit.

Accordingly, the appellate court reversed in part, affirmed in part and remanded the cases for further proceedings. See: Rice v. Correctional Medical Services, 675 F.3d 650 (7th Cir. 2012).

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