BUCEK v. ALLEGHENY COUNTY

CourtDistrict Court, W.D. Pennsylvania
DecidedJuly 2, 2025
Docket2:22-cv-00940
StatusUnknown

This text of BUCEK v. ALLEGHENY COUNTY (BUCEK v. ALLEGHENY COUNTY) is published on Counsel Stack Legal Research, covering District Court, W.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BUCEK v. ALLEGHENY COUNTY, (W.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA DOLORES M. BUCEK, ) ) Administratrix of the ESTATE OF ) 2:22-CV-940-NR MARTIN A. BUCEK, deceased, ) ) ) Plaintiff, ) ) v. )

) ALLEGHENY COUNTY, ) ORLANDO L. HARPER, LAURA ) WILLIAMS, and ALLEGHENY ) ) HEALTH NETWORK, ) ) Defendants. )

OPINION J. Nicholas Ranjan, United States District Judge Plaintiff Dolores M. Bucek brings this action against Defendants Allegheny County, Allegheny County Jail Warden Orlando Harper, Allegheny County Jail Chief Deputy Warden Laura Williams (together, the “County Defendants”), and Allegheny Health Network (AHN) for the death of her husband, Martin Bucek, while in custody as a pretrial detainee at the Allegheny County Jail (ACJ). Her Section 1983 claims for municipal liability and supervisory liability allege that the County Defendants were deliberately indifferent to Mr. Bucek’s vulnerability to suicide. She also brings wrongful-death and survival claims (premised on professional and corporate negligence) against AHN. Defendants now move for summary judgment, arguing that all of the claims fail because there is no evidence that Mr. Bucek’s death, by choking on food, was by suicide. After careful review, the Court will grant summary judgment in the County Defendants’ favor as to the Section 1983 claims, but will deny summary judgment as to the negligence claims against AHN. BACKGROUND The Court construes the facts here in the light most favorable to Ms. Bucek, who is the non-movant. I. Factual Background According to ACJ medical records, Mr. Bucek was treated at UPMC Presbyterian Hospital after he attempted to commit suicide by cutting both his wrists with a box cutter on June 18, 2021. ECF 88-4, p. 69. On June 22, 2021, he was taken to St. Clair Hospital for treatment for his depression, and sought admission into the psychiatric unit. Id., p. 135; ECF 82-10, p. 1. After learning that he would not be admitted, he assaulted a staff nurse, resulting in his arrest and discharge to ACJ. ECF 82-11, pp. 5-6. A. Mr. Bucek’s treatment at ACJ from June 24, 2021 through July 2, 2021. After Mr. Bucek arrived at ACJ, he received a mental-health screening and a mental-health evaluation on June 24, 2021 by Charlotte Porter, a mental-health specialist. She documented that Mr. Bucek was currently feeling depressed, was diagnosed with bipolar schizoaffective disorder over 20 years ago, had 6 previous suicide attempts (including overdosing on drugs, jumping over a bridge, and stabbing himself in the chest), had been with Pittsburgh Mercy’s Community Treatment Team (a community-based program that treats patients with serious mental illnesses) for 13 years, had over 10 inpatient psychiatric admissions, and was taking psychiatric drugs (“Haldol, Vistaril, and something for depression”). ECF 88-4, pp. 149-162. She also documented that Mr. Bucek did not have any current suicidal ideation or plan, but had a history of command auditory hallucinations, including recent hallucinations telling him to harm himself or others on June 18, 2021 and June 22, 2021. Id., pp. 149, 156, 158, 160. She did not think that he was a suicide risk, but she did require a psychiatric evaluation. Id., pp. 158, 163. She recommended admitting him to Pod 5C (the acute mental health male unit that housed inmates with high suicide risk) on regular observation status, which entailed guard tours every 30 minutes. Id., p. 69; ECF 79-7, 52:8-53:25; ECF 82-4, 32:2-5. On June 25, 2021, Mr. Bucek was evaluated by Dr. Ann Hammon, a psychiatrist. Dr. Hammon documented that Mr. Bucek had suicidal ideation, but that he had no immediate suicidal plan. ECF 88-4, p. 135. Mr. Bucek reported that he was very depressed, felt hopeless, and had experienced command auditory hallucinations for a long time. Id. Dr. Hammon recommended putting him on suicide watch,1 and also prescribed Lexapro, Haldol, and Vistaril (medications that Mr. Bucek had been taking). Id., pp. 136, 140. At her deposition, Dr. Hammon testified that she put Mr. Bucek on suicide watch because the evaluation was “just loaded with risk factors”—including low self-esteem, history of suicide attempts, and command hallucinations. ECF 79-3, 48:1-14. Just a day after being placed on suicide watch, Mr. Bucek was seen by Stephen Scharding, a Physician Assistant, who discontinued suicide watch and placed him on regular observation instead. ECF 88-4, pp. 123-128. PA Scharding documented that Mr. Bucek was less depressed, denied any current suicidal ideation, intent, or plans, and agreed to tell staff should they occur, and did not report any agitation or manic

1 Per ACJ suicide-prevention protocols, “suicide watch” actually consists of two different observation levels. An inmate who is “acutely suicidal”—i.e., determined by a qualified healthcare professional to be in imminent danger of committing suicide, actively engaging in self-injurious behavior, or threatening suicide with a specific plan—is placed in an observation cell and is constantly monitored. An inmate who is “non-acutely suicidal”— i.e., expressing current suicidal ideation (expressing a wish to die but without a specific plan) or who has a recent history of self-harm behavior or demonstrates other concerning behavior that may increase their risk of serious injury or death—is observed at staggered intervals not to exceed 15 minutes (“close observation”). ECF 79-2, p. 7; ECF 78-8, pp. 2-3. The mental-health provider determines the appropriate level of observation based on a risk assessment of the inmate. ECF 79-2, p. 7. Dr. Hammon’s note doesn’t specify what type of suicide watch Mr. Bucek was placed on, but PA Scharding’s note suggests that it was “close observation” (staggered 15-minute intervals). ECF 88-4, p. 123. episodes. Id., p. 123. Mr. Bucek also agreed to increasing his Haldol dosage due to his auditory hallucinations. Id., p. 127. At his deposition, PA Scharding explained that he took Mr. Bucek off suicide watch because Mr. Bucek “told [him] he was doing better,” was no longer having suicidal ideations, and “contracted for safety” which meant that “he agreed to tell someone should he become suicidal[.]” ECF 79-12, 33:7- 18. On June 28, 2021, Mr. Bucek was evaluated by Dr. William Fowler, a psychiatrist, after the 5C correctional officer notified mental-health staff that Mr. Bucek was continuously banging on the cell door with his hands, causing bleeding. ECF 88-4, p. 68. Dr. Fowler also documented that he had “swelling of his [right] eye which he is not able to explain.” Id., p. 116. Dr. Fowler didn’t know if the injury on the right eye was self-inflicted. Id. He also recorded Mr. Bucek was having hallucinations that commanded him to harm himself and others, but did not express any suicidal ideation or plan, and that Mr. Bucek “is a danger to self and others.” Id., pp. 120-21. Dr. Fowler ordered STAT (emergency) medication for Mr. Bucek’s agitation and psychosis. Id. At his deposition, he testified that he believed Mr. Bucek’s behavior of banging on the door resulted from his agitation, rather than any indication that he was intentionally harming himself or had suicidal intent. ECF 79- 5, 27:7-16. He further testified that, at the time he evaluated Mr. Bucek, he “didn’t think it made a difference” at that point whether the eye injury was self-inflicted because he was dealing with an “emergency situation” where Mr. Bucek was severely agitated and his purpose there “was to calm [Mr. Bucek] down[,]” and he also had no evidence that the injury was intentional. Id., 42:11-44:11. On June 29, 2021, Maria Ivona Chrzastowska, a Physician Assistant, documented that she evaluated Mr. Bucek’s right eye and bleeding from both ears. ECF 88-4, p. 67. Mr.

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Bluebook (online)
BUCEK v. ALLEGHENY COUNTY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bucek-v-allegheny-county-pawd-2025.