The U.S. Court of Appeals for the Eighth Circuit is reviewing a negligence lawsuit filed by parents whose son committed suicide in an Iowa county jail after meeting with a mental health provider who failed to report critical warning signs to jail staff.
Kent and Leslie Payne, as executors of their son Jordan's estate, sued Eyerly-Ball Community Mental Health Services and employee Scott Thomas following Jordan's death by suicide at the Madison County Jail in Winterset, Iowa. The appeal, filed as *Kent H. Payne v. Eyerly-Ball* (8th Cir. 2026), challenges a district court's grant of summary judgment in favor of the mental health provider.
The tragic incident unfolded on a single day when Jordan Payne met with Thomas, an employee of Eyerly-Ball Community Mental Health Services, while incarcerated at the Madison County Jail. During this meeting, Jordan exhibited clear signs of acute mental health crisis, making several concerning statements that indicated his psychological distress.
Crucially, Jordan told Thomas that he was not "going to kill [himself] here," but could not guarantee what he might do when released from custody. This statement proved prophetic, as Jordan hanged himself approximately 10 minutes after being returned to his cell following the mental health evaluation.
The case hinges on what information Thomas shared with jail personnel after his meeting with Jordan. According to court records, Thomas spoke with jail employee John Weakland following the interview. Thomas told Weakland that "Jordan had specifically told [him] on more than one occasion that he was not going to hurt himself in custody, but he was not sure what would happen when he left."
However, Thomas failed to report Jordan's other concerning statements that had occurred during their meeting. This selective communication proved critical, as Weakland testified that after his conversation with Thomas, he "had no concern that Jordan would harm himself." The incomplete information sharing may have contributed to inadequate suicide prevention measures being implemented.
The timing of events adds urgency to the case's central questions about mental health provider duties. Jordan's suicide occurred just 10 minutes after Weakland returned him to his cell, suggesting that immediate intervention might have prevented the tragedy had jail staff been fully informed of Jordan's mental state.
The Paynes' lawsuit alleges that Thomas and Eyerly-Ball Community Mental Health Services were negligent in their handling of Jordan's case. Specifically, they claim the defendants' failure to adequately communicate Jordan's mental health crisis to jail personnel contributed to his death.
The U.S. District Court for the Southern District of Iowa initially granted summary judgment in favor of Thomas and Eyerly-Ball on the negligence claims. The district court's reasoning focused on whether the mental health provider owed a duty of care to Jordan and whether their actions constituted a breach of professional standards.
The Eighth Circuit's review will examine several critical legal questions surrounding mental health provider liability in correctional settings. The case tests the boundaries of professional responsibility when mental health workers interact with incarcerated individuals who may pose suicide risks.
Key issues before the appeals court include the scope of duty owed by private mental health contractors to inmates, the standard of care required when communicating suicide risk assessments to correctional staff, and whether partial disclosure of concerning statements can constitute negligence when more complete information might have prevented harm.
The case also raises broader questions about mental health care delivery in jail settings, where coordination between outside providers and correctional staff is essential for inmate safety. The outcome could establish important precedent for how mental health professionals must communicate risk assessments in correctional environments.
Jail suicide represents a persistent challenge in correctional facilities nationwide, with mental health crises often going unrecognized or inadequately addressed. The *Payne* case highlights the critical importance of comprehensive communication between mental health providers and jail personnel when assessing suicide risk.
The case was submitted to the three-judge panel on Sept. 18, 2025, and the court filed its opinion on Jan. 6, 2026. The panel consists of Circuit Judges Smith, Gruender, and Shepherd, with Judge Shepherd writing the opinion.
For the Payne family, the appeal represents their effort to hold mental health providers accountable for what they view as inadequate professional care that contributed to their son's death. The outcome will likely influence how mental health services are delivered in correctional settings and establish standards for provider communication with jail staff.
The Eighth Circuit's decision will provide important guidance on mental health provider liability in correctional settings and could affect policies governing suicide prevention protocols in jails across the circuit's jurisdiction, which includes Iowa, Missouri, Arkansas, Nebraska, North Dakota, South Dakota, and Minnesota.