Brooks v. Dept. of Rehab. & Corr.
2016 Ohio 7810
| Ohio Ct. Cl. | 2016Background
- Brooks, a former inmate, sued the Ohio Department of Rehabilitation & Correction for negligence over two inmate attacks; liability was previously found only for the October 28, 2011 BeCI incident.
- On October 28, 2011 Brooks was pulled from a top bunk (~5–6 ft), fell to concrete, and reported wrist, low-back and buttock pain; he was taken to the infirmary, given Tylenol and rest.
- Brooks later transferred among several institutions (SCI, RCI, AOCI, TCI), reported continuing back pain at times, received various pain medications in custody and post-release treatment (MRI, x‑ray, PT, Gabapentin, Tramadol).
- Defendant’s expert orthopedist (Dr. Brodell) reviewed records and examined Brooks, diagnosing advanced cervical spondylosis as preexisting and only a mild lumbosacral contusion from the fall that resolved without residuals.
- Magistrate found the record supports a short‑term injury from the fall (temporary pain resolving within weeks) and rejected Brooks’s claim of repeated kicks and of long‑term causation without expert support.
- Magistrate awarded Brooks $6,500 for past pain and suffering plus $25 filing fee (total $6,525); no recovery for medical expenses or lost wages because state paid medical care in custody and plaintiff did not prove entitlement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Causation of long‑term back/neck injury | Brooks: fall caused ongoing back pain requiring later imaging and treatment | State: expert shows degenerative cervical spondylosis preexisted; fall caused only mild, resolving lumbosacral contusion | Held: No admissible expert link from fall to long‑term maladies; fall caused temporary injury only |
| Scope of physical injury (kicking after fall) | Brooks: was kicked multiple times while on floor, causing rib/other injuries | State: medical records and Brooks’s deposition do not support post‑fall beating; contemporaneous notes describe fall only | Held: Magistrate disbelieved multiple kicks; record supports only the fall and immediate pain |
| Proof required for long‑term damages | Brooks: subjective reports and later treatment show continuity of injury | State: need expert testimony to prove long‑term internal injury causation and duration | Held: Expert causation required for claimed long‑term internal conditions; plaintiff failed to provide such proof |
| Recovery of medical expenses and lost wages | Brooks: seeks damages including medical expenses/lost wages | State: medical care in custody paid by state; no proof of out‑of‑pocket or lost earnings tied to incident | Held: Plaintiff not entitled to recover medical expenses or lost wages; awarded only past pain & suffering and filing fee |
Key Cases Cited
- No officially reported cases with reporter citations were cited in the magistrate's decision. The opinion references unpublished or regional decisions and authorities without official reporter citations.