Aubrey Lauhoff v. Quality Correctional Health Care, Inc.
707 F. App'x 614
| 11th Cir. | 2017Background
- Plaintiff Aubry Lauhoff, incarcerated in Lawrence County Jail, had diagnosed Crohn’s disease, anemia, edema, and malnourishment and received jail treatment (labs, medications, B12). He was hospitalized six days after release and received a blood transfusion for severe anemia.
- Lauhoff sued under 42 U.S.C. § 1983 alleging deliberate indifference by Dr. Johnny Bates (and QCHC) in providing constitutionally adequate medical care while jailed. Other claims were voluntarily dismissed, leaving only the § 1983 deliberate-indifference claim.
- At trial the district court instructed the jury using the Eleventh Circuit pattern definition of “serious medical need,” and, at Lauhoff’s request, added that “serious harm does not require a permanent loss or handicap.”
- Lauhoff requested additional language that “serious harm includes unnecessary pain and suffering”; the court refused that portion. Lauhoff objected and renewed the objection after the court re-read the pattern instruction during deliberations.
- The jury found Lauhoff had a serious medical need and that Dr. Bates knew it posed a risk of serious harm, but found Dr. Bates did not act with deliberate indifference (i.e., did not fail to provide necessary care in disregard of risk). The district court denied Lauhoff’s motion for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court erred by refusing to instruct that “serious harm” includes unnecessary pain and suffering | Lauhoff: the omitted language was a correct statement of law and essential to show harm; its absence misled jurors and warrants a new trial | Defendants: the pattern instruction adequately defined serious medical need; the requested language was unnecessary and would not change outcome | Court: No abuse of discretion. Pattern instruction was legally adequate and omission caused no prejudice because jury found first two elements for Lauhoff and rejected deliberate indifference on the third |
Key Cases Cited
- Lamonica v. Safe Hurricane Shutters, Inc., 711 F.3d 1299 (11th Cir. 2013) (standard of review for jury instructions and refusal to give requested instruction)
- Badger v. S. Farm Bureau Life Ins. Co., 612 F.3d 1334 (11th Cir. 2010) (verdict will not be disturbed unless charge as a whole is erroneous and prejudicial)
- Mann v. Taser Int’l, Inc., 588 F.3d 1291 (11th Cir. 2009) (definition/analysis concerning serious medical need)
- Conroy v. Abraham Chevrolet-Tampa, Inc., 375 F.3d 1228 (11th Cir. 2004) (district court has wide discretion over language of instructions if they accurately reflect law)