Sanchez v. Young County

What This Case Is About

Diana Simpson died of a drug overdose while a pretrial detainee at the Young County Jail. Her family sued Young County under § 1983, alleging the county’s policies and customs regarding jail intake procedures constituted deliberate indifference to detainees’ serious medical needs. On the second appeal, the Fifth Circuit reversed summary judgment for the county on the conditions-of-confinement theory, finding genuine issues of material fact.

The Facts

Simpson’s husband knew she was suicidal—she had previously told him that if she tried again, she would withdraw cash, go to a motel, and overdose on pills. When he noticed a cash withdrawal and couldn’t reach her, he filed missing-person reports. Police found Simpson asleep in her vehicle on the side of a road. Her speech was slurred, she could barely keep her eyes open, and she needed assistance walking. Officers found empty blister packs for twenty-four pills in her car, including antihistamines, muscle relaxers, and antipsychotics. When asked how much she had taken, she said “all of it.” She told a medic she was trying to kill herself, though she denied it to officers.

Officers arrested Simpson for public intoxication and took her to Young County Jail. During the book-in process, jailers completed only the detainee-question portion of the suicide-screening form, leaving the jailer-observation portion blank. They never completed the computer-based medical intake form. They did not review the state-mandated Continuity of Care Query results, which would have confirmed that Simpson had received state-provided mental health services. Because they thought Simpson was merely drunk, jailers put her in a holding cell at 6:30 p.m. to “sleep it off.” Simpson died.

What the Court Decided

The Fifth Circuit reversed summary judgment for the county on the conditions-of-confinement claim. The court found that the plaintiffs had raised genuine issues of material fact regarding whether the jail had a persistent pattern and practice of failing to complete mandatory intake screening forms. Multiple jailers testified that intake forms did not have to be completed at the time of booking and could be done later—contrary to mandatory state regulations.

The court held that a reasonable jury could find that the jail’s custom of deferring mandatory intake screenings constituted a condition of confinement that reflected deliberate indifference to detainees’ serious medical and mental health needs. The incomplete screening process was the moving force behind the failure to identify Simpson as a suicide risk and provide appropriate intervention.

Why This Case Matters for Your § 1983 Case

Conditions-of-confinement claims focus on systemic failures. Unlike episodic-acts claims (which focus on individual officer decisions), conditions-of-confinement claims target the policies and customs that create dangerous conditions in the jail. This distinction matters for Monell liability.

Incomplete intake screenings can constitute deliberate indifference. When a jail has mandatory screening procedures but routinely fails to complete them, that pattern can establish the custom element required for municipal liability.

“Sleeping it off” is not medical care. Placing a detainee who shows signs of overdose or suicidal ideation in a cell without completing medical screening or providing appropriate monitoring can constitute deliberate indifference to serious medical needs.

State regulations create the standard of care. State-mandated intake procedures, such as Texas’s Continuity of Care Query requirements, help establish what constitutes reasonable care and what constitutes a departure from it.

Key Takeaway

When a jail has a persistent custom of failing to complete mandatory intake screening forms—and a detainee dies as a result of the information those forms would have revealed—the county may be held liable under § 1983 for maintaining unconstitutional conditions of confinement. This case demonstrates that systemic failures in booking and intake procedures, not just individual officer negligence, can give rise to municipal liability under the Fourteenth Amendment.