Vallejo suffered severe brain damage in an aborted suicide attempt while detained in a cell at the Rahway Police Department. He brought, inter alia, a negligence claim against the Department and the municipality. It was undisputed that Vallejo was intoxicated when placed in the cell. The Superior Court, Union County, in its instruction to the jury on the negligence claim, stated that the plaintiff's "helpless intoxication" would constitute a "special circumstance" giving rise to a duty on the part of his jailers to prevent him from committing suicide.
Held: Inter alia, the verdict for the defendants on the negligence claim is reversed and the claim is remanded for a new trial. The instruction might have misled the jury into believing that it had to find "helpless intoxication" instead of mere intoxication before it could find special circumstances.
| Michael Welner, M.D. Chairman The Forensic Panel |
Dr. Welner comments: Suicide is not actually caused by anything other than the instrument of death and the state of mind, depressed or desperate, that chooses death. Yet a number of factors are associated with a higher risk of suicide, including alcohol. Alcohol doesn't cause suicide, but may abet it. How does this occur?
Alcohol, while generally understood as a central nervous system' depressant, is associated with suicide by its tendency to weaken impulse control. This is the same mechanism for most of the criminality, violence and other behavioral problems attributed to alcohol.
Degree of intoxication is not as important as the lower court suggested. Even at lower levels of intoxication, disinhibition commonly occurs. Most people appreciate these effects for their social benefits. However, disinhibition to a distraught individual can make a difference between a desperate, self-injurious impulse not acted upon and an actual suicidal attempt.
At higher levels of intoxication, an individual experiences the central nervous system depressant effects of alcohol more strongly, and consequently may become too stuporous to meaningfully act on impulses. Even the Superior Court correctly pointed out that, "we are at a loss that a person who is so profoundly intoxicated that he is considered helpless can be considered at risk for such a coordinated series of actions."