From the Courts: Failure to Train; Restrictive Housing
Author: Ken Kozlowski.
Source: Volume 27, Number 03, Summer 2026 , pp.55-56(2)

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Abstract:
Our regular review of federal appellate rulings includes two cases: The United States Court of Appeals for the Eighth Circuit held that an inmate's estate plausibly alleged deliberate indifference claims against three jail nurses and a failure-to-train claim against the county arising from an inmate's fatal stroke, requiring reinstatement of those claims while affirming dismissal of claims against other defendants. The United States Court of Appeals for the Third Circuit affirmed summary judgment for prison officials, holding that prolonged restrictive housing of a mentally ill inmate did not constitute deliberate indifference or violate due process where officials regularly reviewed his placement, provided ongoing mental health treatment, and based housing decisions on legitimate security concerns rather than disability.Keywords: Deliberate Indifference; Correctional Health Care; Failure to Train; Restrictive Housing; Mental Health
Affiliations:
1: Contributing Editor.