Iannelli v. County of Nassau

Summary

The Appellate Division, Second Department, affirmed the denial of the defendants' motion for summary judgment in an action arising from a detained plaintiff's suicide attempt by jumping from a police station window. The court held that triable issues remained concerning whether the defendants knew or should have known of the plaintiff's risk of self-harm and whether they provided adequate supervision and medical care. Triable issues also remained regarding assault and battery, civil rights violations under 42 USC § 1983, and loss of consortium.

Holdings

1. A county owes a duty of care to protect its prisoners from self-inflicted harm, but it is not an insurer of prisoner safety; liability depends on whether the risk of harm was reasonably foreseeable because the county knew or should have known of it.
2. The defendants were not entitled to summary judgment because their submissions failed to eliminate triable issues of fact as to whether they knew or should have known that Carol Iannelli posed a risk of harm to herself and whether they failed to provide adequate supervision to prevent reasonably foreseeable harm.
3. The defendants failed to eliminate triable issues of fact concerning the alleged violation of 42 U.S.C. § 1983, assault and battery, and the loss-of-consortium claim.

Questions Presented

1. Whether the defendants were entitled to summary judgment on the ground that Carol Iannelli's suicide attempt was not reasonably foreseeable.
2. Whether the defendants eliminated triable issues of fact concerning negligent supervision and failure to protect a detainee from self-inflicted harm.
3. Whether the defendants eliminated triable issues of fact concerning alleged deprivation of adequate medical care under 42 U.S.C. § 1983, assault and battery, and Louis Iannelli's loss-of-consortium claim.

Disposition

affirmed