Background
Tiffany Barringer’s 18-year-old son, Peyton Barringer, died by suicide while visiting the Tennessee home of his father, Shawn Jones, and stepmother, Sara Jones. About a year earlier, Peyton had attempted suicide by overdosing on insulin. Sara knew about that attempt, Peyton’s continuing therapy, his depression and poor sleep, and an unsecured .22-caliber rifle and ammunition in the home. Peyton’s family had also established a routine under which he administered insulin in Shawn’s or Sara’s presence.
On November 7, 2022, Sara observed no unusual behavior indicating an imminent suicide attempt. Sometime that night or the next morning, Peyton used his father’s rifle to take his own life. Barringer sued Sara for wrongful death, alleging that her negligence allowed Peyton access to the unsecured weapon. The district court granted Sara summary judgment, concluding that Peyton’s suicide was not reasonably foreseeable, and Barringer appealed.
The Court’s Holding
The Sixth Circuit affirmed. Applying Tennessee law, the court held that Barringer could not establish proximate cause because the evidence did not permit a rational jury to find that Peyton’s suicide was a reasonably foreseeable probability when the alleged negligence occurred. Sara’s knowledge of Peyton’s prior attempt, therapy, depression, poor sleep, and the insulin-supervision routine showed a lingering, appreciable suicide risk, but not acute suicidality or active contemplation of suicide on November 7.
The court acknowledged that Sara’s deletion of all her text messages with Peyton after his death could undermine her credibility. But disbelief of Sara’s testimony was not affirmative evidence of what the deleted messages contained and could not support an inference that Peyton had communicated suicidal thoughts or distress. Because Barringer bore the burden of proving foreseeability, the deletion alone could not defeat summary judgment.
The court also rejected Barringer’s reliance on Tennessee’s special-relationship exception to the traditional suicide rule. In this context, the exception is confined to relationships of a medical nature. Neither the stepmother-stepson relationship nor the homeowner-household-member relationship qualified.
Key Takeaways
- Under Tennessee law, a prior suicide attempt and general awareness of continuing depression do not, without more, make a later suicide a reasonably foreseeable probability.
- The relevant inquiry was whether Sara should have perceived an acute suicide risk or active contemplation of suicide when Peyton was exposed to the alleged negligence.
- Deleting relevant communications may undermine a witness’s credibility, but disbelief alone does not supply affirmative evidence needed to prove an essential element at summary judgment.
Why It Matters
The decision applies Tennessee’s foreseeability-centered approach to suicide-related negligence claims. Even when a defendant knows of a prior attempt and maintains precautions against suicide, a plaintiff must present solid evidence that the suicide was a foreseeable probability at the time of the alleged negligence, rather than merely a continuing possibility.
The opinion also clarifies that Tennessee’s special-relationship route to proximate cause in suicide cases does not extend to ordinary family or household relationships and illustrates the limits of credibility disputes involving missing evidence at summary judgment.