Stewart v. Turner et al

In 2015, Michael Stewart, a pretrial detainee at the Salt Lake County Jail, died by suicide after being taken off prescribed psychiatric medication and placed in isolation. Despite his visible mental deterioration and multiple requests for help, correctional officer Cody Turner and other jail staff failed to provide medical intervention. Stewart’s mother, Lonnie Stewart, as the representative of his estate, filed a 42 U.S.C. § 1983 suit alleging deliberate indifference to serious medical needs in violation of the Eighth and Fourteenth Amendments. The district court granted summary judgment to the defendants. On June 29, 2023, the U.S. Court of Appeals for the Tenth Circuit partially reversed, holding that a reasonable jury could find Officer Turner subjectively aware of a substantial suicide risk yet unreasonably failed to act. The case was remanded for further proceedings.

The Tenth Circuit Court of Appeals reversed the district court’s grant of summary judgment in part, reinstating the deliberate indifference claim against Officer Turner and remanding the case for trial.

Whether correctional officer Cody Turner acted with deliberate indifference to Michael Stewart’s known risk of suicide, thereby violating his constitutional rights.

The decision refined the subjective awareness standard for deliberate indifference claims in jail suicide cases, emphasizing that ignoring obvious symptoms of a mental health crisis can constitute a constitutional violation. It prompted scrutiny of correctional mental health protocols and training on suicide prevention.