Civil Rights – 14th Amendment-Jury Instructions

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7^th Circuit Court of Appeals

Case Name: Reginald Pittman v. Madison County, Illinois

Case No.: 23-2301

Officials: Rovner, Hamilton, and Scudder, Circuit Judges.

Focus: Civil Rights – 14^th Amendment-Jury Instructions

Reginald Pittman, a pretrial detainee at the Madison County jail, attempted suicide and sustained a severe brain injury. He alleged that two guards ignored his requests for crisis counseling before his attempt. Pittman subsequently sued Madison County and several jail officials under 42 U.S.C. § 1983, claiming a violation of the 14th Amendment due to inadequate medical care. The case has undergone three appeals and three trials.

Initially, the Southern District of Illinois granted summary judgment in favor of the defendants. This decision was partially overturned by the Seventh Circuit in Pittman I. After the first trial, the Seventh Circuit in Pittman II reversed and remanded the case for a new trial due to the wrongful exclusion of evidence. In Pittman III, the Seventh Circuit identified a jury instruction error and remanded for a third trial. During this third trial, the district court instructed the jury according to the guidance from Pittman III, requiring proof that the officers were subjectively aware of or strongly suspected a high likelihood of self-harm. The jury ultimately ruled in favor of the defendants.

The Seventh Circuit found the jury instruction to be flawed. The court clarified that Pittman was not required to prove the defendants’ subjective awareness of the risk. Instead, the jury should have been instructed to determine whether the defendants made an intentional decision regarding Pittman’s conditions of confinement and whether they acted objectively unreasonably by failing to mitigate the risk. Despite this instructional error, the court concluded that it did not prejudice Pittman, as the case essentially boiled down to a credibility contest between the guards’ and the inmate’s testimonies.

Affirmed.

Decided 07/16/24

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