Norman Whitney, Sr. v. City of St. Louis, Missouri

Summary

The Eighth Circuit affirmed dismissal of §1983 deliberate indifference claims after a pretrial detainee's suicide, holding that the complaint failed to allege the corrections officer had actual knowledge of the suicide risk, satisfying the subjective prong. Without an underlying constitutional violation by a city employee, municipal liability under *Monell* could not attach, even if the city lacked a constant surveillance policy. The court also rejected reliance on unnamed officials' knowledge as insufficient to plead deliberate indifference.

Holdings

1. The complaint failed to allege that Sharp had actual knowledge of Whitney's suicide risk, as required for the subjective prong of deliberate indifference.
2. Absent a constitutional violation by a city employee, there can be no § 1983 or Monell liability for the City.

Questions Presented

1. Whether the district court erred in holding that the complaint did not adequately plead deliberate indifference against Sharp.
2. Whether the district court erred in holding that the City could not be liable under § 1983 in the absence of a constitutional violation by Sharp.

Disposition

affirmed