JORDAN VENEMA, as personal representative of the estate of Tyler Venema, deceased v. FRED WEST and CURTIS KEYS, JODI L. DEANGELO, Warden - Articles

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JORDAN VENEMA, as personal representative of the estate of Tyler Venema, deceased v. FRED WEST and CURTIS KEYS, JODI L. DEANGELO, Warden

Posted by: Azya Thornton on Apr 3, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: John L. Thurber, Joshua S. Smith, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellant.

Attorneys 2: ON BRIEF: Matthew D. Klakulak, Andrew J. Laurila, GIROUX PAPPAS TRIAL ATTORNEYS, Southfield, Michigan, for Appellee.

Judge(s): CLAY, WHITE, and NALBANDIAN, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Flint

CLAY, Circuit Judge. This civil rights action arises from the suicide of Tyler Venema. Venema asphyxiated himself with a plastic bag while in the custody of the Michigan Department of Corrections (“MDOC”) and in an inpatient mental health treatment program at Woodland Center Correctional Facility (“WCC”). Defendant Jodi DeAngelo was the warden of WCC at the time of Venema’s death. Venema’s Estate sued DeAngelo in her individual capacity pursuant to 42 U.S.C. § 1983, alleging that DeAngelo was liable for Venema’s death in violation of the Eighth Amendment. Asserting the defense of qualified immunity, DeAngelo moved to dismiss the claim against her. The district court denied the motion, concluding that DeAngelo was not entitled to qualified immunity. DeAngelo timely appealed. For the reasons set forth below, we affirm.

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