“Confirmed Judges, Confirmed Fears” is a blog series documenting the harmful impact of President Trump’s judges on Americans’ rights and liberties. It includes judges nominated in both his first and second terms.
What’s at stake in this case?
The mother of a prisoner who committed suicide claimed that the prison and officials created dangerous conditions that were responsible for her son’s death.
What happened in this case?
A year after his attempted suicide at another state prison in Missouri, Austen May hung himself in a prison cell in his then-current prison. Kristine Williams, May’s mother, filed suit against the prison system and several individual prison officials, contending that they were deliberately indifferent to a “dangerous condition” responsible for the suicide--- a defective video monitoring system, an obstruction by May that covered his cell window, and failure to make “regular checks” of the cell. The district court rejected a motion to dismiss the complaint and allowed the case to proceed.
The defendants appealed to the Eighth Circuit. In August, Trump judge David Stras joined a decision by George W Bush judge Bobby Shepherd that reversed the lower court and ruled that it should grant immunity to the officials and the prison system. Obama judge Jane Kelly dissented in Williams v Missouri Dep’t of Corrections. The majority maintained that Williams “alleged no more than the absence of preventative measures and a failure to supervise or train, neither of which support” the “dangerous conditions” exception to immunity.
Why did Judge Kelly dissent?
Judge Kelly explained that the majority had misconstrued the facts and case law as related to the “dangerous conditions” exception, contending that Wiliams had “plausibly alleged” that the prison had a “defective video monitoring system” and allowed covering of May’s cell window, which led to May’s suicide. Further “factual development,” she wrote, should have been allowed to determine whether the prison system and officials were liable.
Why is the decision harmful?
The decision made possible by Trump judge Stras clearly deprived Kristine Williams of any remedy for the actions and inactions of state prison officials that she contended led to her son’s death by suicide. It also sets a bad precedent concerning the evaluation of claims that official actions have led to suicides and related injuries under the “dangerous conditions” doctrine, particularly in the Eighth Circuit, which includes Arkansas, Missouri, Iowa, Minnesota, Nebraska, and North and South Dakota. In addition, it illustrates the importance of our federal courts to health, welfare and justice and the significance of having fair-minded judges on the federal bench.