Coleman County, Texas v. Patsy K. Cope, et al.

Petitioner Coleman County is a small, rural county in the State of Texas. In 2017, a pretrial detainee committed suicide in the Coleman County jail. In ensuing litigation, the Fifth Circuit ordered qualified immunity for all individual officers, and this Court denied certiorari. On remand, the only remaining claim was for municipal liability against Coleman County. A split panel of the Fifth Circuit held that a conditions-of-confinement claim derived from the Bell v. Wolfish line of cases could proceed against Coleman County, even though the County was not liable under Monell because (1) there was no constitutional violation caused by a policy of the County; and, (2) no deliberate indifference by jail officials. The panel majority did not explain how the County could be liable under Bell while at the same time not be liable under the traditional Monell framework. The questions presented are:

1. Does a Bell v. Wolfish conditions-of-confinement claim for detainee suicide allow a plaintiff to bypass the traditional Monell test for imposing liability on a municipality?

2. Does a Bell v. Wolfish conditions-of-confinement claim for detainee suicide against a municipality require a demonstration of causation and deliberate indifference?