Joshua W. Barbee v. C/O Johnson, Lt. Walsh, and C. Crow (Warden, BMRCC)

Summary

The United States District Court for the Southern District of Illinois conducted preliminary screening under 28 U.S.C. § 1915A of Joshua W. Barbee’s § 1983 complaint concerning an alleged suicide attempt and requests for mental health care. The court allowed an Eighth Amendment deliberate-indifference claim to proceed against defendants Johnson and Walsh, while dismissing the medical-care claim, defendant Crow, and official-capacity claims without prejudice.

Holdings

1. Barbee plausibly stated a deliberate-indifference claim against Johnson and Walsh because he alleged that he expressly reported his intent to harm himself and requested a crisis team, yet the defendants failed to take reasonable steps to obtain mental-health assistance.
2. The mental-health deliberate-indifference claim was dismissed as to Crow because Barbee did not allege that Crow learned of the request for mental-health care or the risk of self-harm until after Barbee had already cut himself.
3. Barbee failed to state a claim that Johnson, Walsh, or Crow were deliberately indifferent to his medical needs after he cut himself, and Count 2 was dismissed without prejudice.
4. The official-capacity claims against the individual defendants were dismissed without prejudice because monetary damages may be pursued against state officials only in their individual capacities under the allegations presented.

Questions Presented

1. Whether Barbee plausibly alleged that Johnson and Walsh were deliberately indifferent to a serious risk of suicide and serious mental-health needs in violation of the Eighth Amendment.
2. Whether Barbee plausibly alleged that Johnson, Walsh, or Crow were deliberately indifferent to his serious medical needs after he cut himself.
3. Whether Barbee's official-capacity claims for monetary damages could proceed.
4. Whether Crow could be held liable for deliberate indifference to Barbee's request for mental-health care when Crow allegedly became aware of the situation only after Barbee injured himself.

Disposition

other