Brian Zimmermann v. Scott Labish -Eastern District of Michigan at Detroit
Split Score
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Case Summary
Disposition
Reversed
The Sixth Circuit reversed the district court’s refusal to dismiss claims arising from a student’s suicide after a school suspension. The panel held that, although the circuit recognizes the state-created-danger doctrine, it does not apply to a non-custodial suicide, so the officials and municipal entities are entitled to qualified and governmental immunity and the case is dismissed.
Circuit Split Identified
Legal Issue
Whether the Fourteenth Amendment's state-created-danger doctrine extends to make school officials liable for a non-custodial student’s suicide.
Circuit Positions
State-created-danger doctrine can impose §1983 liability on school officials for a non-custodial student’s suicide (Armijo v. Wagon Mound Public Schools).
State-created-danger doctrine does not extend to non-custodial suicide; no §1983 liability for school officials in such circumstances.
Conflict Summary
The Tenth Circuit has held that school officials may incur §1983 liability under the state-created-danger doctrine when a suspended student later commits suicide off-campus, whereas the First, Third, Sixth, Seventh, and Eleventh Circuits have rejected liability for non-custodial suicides, concluding that suicide is a self-inflicted harm that breaks the causal chain and falls outside the doctrine.