Lucas v. City of Long Beach

In Lucas v. City of Long Beach (1976) 60 Cal.App.3d 341, a 17-year-old boy was booked on drunk driving charges, arriving at the juvenile detention facility exhibiting "the symptoms of a moderately intoxicated person." (Id. at pp. 471-472.) Several hours after being placed in a cell, the boy was discovered hanging from a noose fashioned from cloth torn from a mattress cover in an apparent suicide. (Id. at p. 472.) The Court of Appeal noted the boy had "evidenced emotional upset by crying and expressing concern as to the effect that his arrest would have on his mother," but found "not a scintilla of evidence in the record indicating that his conduct was any different than one might expect of a person intoxicated on either drugs or alcohol." (Id. at pp. 349-350.) Nevertheless, the Court of Appeal found that because the boy had "manifested only the symptoms of intoxication," and no obvious signs of being suicidal, the Government Code immunities for failure to provide medical care to prisoners applied. (Lucas, supra, at p. 350.) There was also evidence that a defendant police officer had not made the hourly observations required by state regulations, failing to check on the boy for a period of 2 hours and 55 minutes prior to the discovery of his suicide attempt. (Id. at p. 345.) The Court of Appeal found, however, that this was not a special circumstance justifying departure from the general rule that a jailer is not liable for a prisoner's suicide, describing the jury's finding that such an hourly inspection would have prevented the suicide to be "pure speculation." (Id. at p. 351.) The court concluded that the boy's own intentional act was "highly unusual and not foreseeable," and therefore the superseding cause of harm and the legal cause of his death. (Id. at p. 351.) On that basis, the Court of Appeal reversed the jury's verdict against the defendant city and police officer. (Ibid.)