Whether jail officials violate a pretrial detainee's Fourteenth Amendment right to medical treatment by being reckless to, without actually knowing of, the detainee's substantial risk of suicide

Questions Presented 1. Whether pursuant to Kingsley v. Hendrickson, 135 S.Ct. 2466 (2015), jail officials violate a pretrial detainee’s Fourteenth Amendment right to medical treatment by being reckless to, without actually knowing of, the detainee’s substantial risk of suicide. 2. Whether the Tenth Circuit erred by concluding, contrary to other jurisdictions, that suicide is not a highly predictable consequence of a detention center’s failure to enforce a suicide prevention program. i Rule 14(b)(i) Statement The are as follows: Gary Heidel, Individually; Michelle Aschbacher, individually; Camille Rowell, individually; Kersten Heidel, individually; and Michael Rowell, individually and as the personal representative of the Estate of Catherine Rowell. The are as follows: Sherriff Anthony Mazzola, in his individual and official capacity; Sergeant Jeremy Muxlow, in his individual capacity; Deputy Kim Cook, in his individual capacity; Deputy Clinton Kilduff, in his individual capacity; and Deputy Johnny Murray, in his individual capacity. Rule 14.1(b)(iii) Statement This case directly relates to these proceedings: Heidel, et. al., v. Mazzola, et. al., (D. Colo. No. January 28, 2020). Heidel et. al. v. Mazzola, et. al. (10th Cir. No. 20-1067, March 23, 2021). Heidel, et. al., v. Mazzola, et. al., (Colorado, Adams County Court No. 2020CV30602, no judgment, filed to pursue state-law claims after the grant of summary judgment on the federal claims). ii Heidel, et. al., v. Mazzola, et. al., (Colorado, Rio Blanco County Court No. 2020CV1, no judgment yet, transferred to this court from Adams County court). Heidel, et. al., v. Mazzola, et. al., (Colorado Court of Appeals No. 2021CA370, no judgment yet, interlocutory appeal from the Rio Blanco County case). No other proceedings in state or federal trial or appellate courts, or in this Court, directly relate to this case. iii