Donald Nichols v. Knox Cty., Tenn.
16-6492
6th Cir.Dec 6, 2017Background
- While incarcerated at Knox County Detention Facility, Donald Nichols fell from a top bunk and fractured his neck; he sought medical care repeatedly but did not receive x-rays or a proper diagnosis until 70 days later.
- Nichols sued Knox County and several jail medical/staff employees under 42 U.S.C. § 1983 (deliberate indifference). He also pursued related state-law suits; the state court granted summary judgment to the County on the negligence bunk-assignment claim.
- Nichols settled with individual defendants, including Nurse Amy Luxford, who paid $187,500 and was dismissed in both individual and official capacities; Nichols retained separate Monell claims against the County.
- The County admitted liability under § 1983 for damages proximately caused by the 70-day diagnostic delay; the district court entered summary judgment on liability for those injuries, leaving damages to a jury.
- The jury awarded Nichols $140,000 for pain, suffering, mental anguish, and loss of dignity caused by the delay; the County appealed raising multiple issues (effect of Luxford settlement, setoff, evidentiary rulings, jury instructions, and res judicata).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Effect of Luxford settlement on County claims | Settlement released only Luxford; Monell claims against County remain distinct | Settlement of official-capacity claim against Luxford discharged County liability, leaving no case or controversy | Held for Nichols: settlement did not extinguish separate municipal (Monell) claims against County |
| Setoff of jury verdict by Luxford payment | No setoff because County’s liability for municipality-based policies was distinct and jury never assessed Luxford’s liability | County sought setoff of $140,000 verdict by Luxford’s $187,500 settlement as duplicative recovery | Held for Nichols: no setoff; jury considered only County liability and Luxford denied liability in settlement |
| Admissibility of Luxford settlement at trial | Settlement irrelevant to County-only damages determination; exclusion appropriate | County sought to inform jury of settlement to reduce verdict (comparative fault/setoff) | Held for Nichols: district court within discretion to exclude settlement evidence; comparative fault inapplicable under federal law here |
| Res judicata based on Tennessee negligence dismissal | § 1983 claim arises from different operative facts (failure to diagnose/treat) than state negligence housing/bunk-assignment claim | State-court negligence judgment bars federal § 1983 suit (same transaction) | Held for Nichols: res judicata does not apply; state case addressed different facts; motion to certify state-law questions denied |
Key Cases Cited
- Monell v. Dep’t of Soc. Servs. of N.Y.C., 436 U.S. 658 (municipalities liable under § 1983 only for official policy or custom)
- Moldowan v. City of Warren, 578 F.3d 351 (6th Cir.) (official-capacity release does not necessarily extinguish separate municipal claims)
- Gregory v. City of Louisville, 444 F.3d 725 (6th Cir.) (affirming that municipal Monell liability can survive dismissal of individual-capacity claims)
- Dobson v. Camden, 725 F.2d 1003 (5th Cir.) (setoff applicable only when settling and non-settling parties are jointly liable for same injury)
- Weeks v. Chaboudy, 984 F.2d 185 (6th Cir.) (no joint liability when injury is divisible and causation can be separately assigned)
- Edmonds v. Compagnie Generale Transatlantique, 443 U.S. 256 (federal setoff principles and divisible injuries)
- Restivo v. Hessemann, 846 F.3d 547 (2d Cir.) (no setoff where a settling party’s liability was not considered by the jury)
- Ventas, Inc. v. HCP, Inc., 647 F.3d 291 (6th Cir.) (standards for reviewing jury instructions)
- Creech v. Addington, 281 S.W.3d 363 (Tenn.) (Tennessee res judicata principles: same cause of action requires same transaction or nucleus of operative facts)
- Heyliger v. State Univ. & Cmty. Coll. Sys. of Tenn., 126 F.3d 849 (6th Cir.) (federal courts give state-court judgments the preclusive effect they would receive under state law)
- Pennington v. State Farm Mut. Auto. Ins. Co., 553 F.3d 447 (6th Cir.) (declining state certification where federal court can follow a clear, principled course)