Court Rules that Inmate Who Creates His Filthy Cell Conditions Does Not State a Constitutional Claim

March 29, 2017

In Key v. Juegens, et al., a jail inmate, Dajuan Key, alleged that defendant correctional officers and a social worker violated his rights based on his living conditions in his cell and their failure to provide him with mental health services while he was on suicide watch for 9 days. U.S. District Court Judge James Shadid granted summary judgment in defendants’ favor, finding that the undisputed facts demonstrated that the defendant correctional officers saw Key only twice during the 9-day period: (1) when he was placed on suicide watch and seen by the jail social worker and (2) 2 days before he saw the social worker again and was removed from suicide watch. The Court found that, at most, Key suffered from a 2-day delay in mental health treatment and that Key had not presented any evidence that his mental condition deteriorated during those 2 days, entitling defendants to summary judgment. Judge Shadid also found that Key’s cell conditions (feces on the walls and standing water) was caused by him smearing feces and flooding his toilet. Key had multiple opportunities and the capability to clean his cell, but he chose not to. Therefore, the Court concluded, defendants could not be held liable for the condition of the cell. Michael Condon and Yordana Wysocki represented the defendant officers.

Key v Juergens, et al

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