Estate of Cindy Lou Hill v. Naphcare, Inc.
23-2741
9th Cir.Apr 14, 2025Background
- NaphCare, Inc. provided medical services to the Spokane County Jail, where Cindy Lou Hill died in custody from acute bacterial peritonitis after being observed by medical and non-medical jail staff.
- Hill had complained of severe abdominal pain and was transferred to the "medical watch" area, monitored mainly by correctional officers without medical training rather than by healthcare professionals.
- Hill’s estate sued NaphCare under 42 U.S.C. § 1983 for municipal/Monell liability, alleging deprivation of her constitutional right to adequate medical care, as well as negligence under state law.
- The jury found NaphCare liable under both claims, awarding $2.475 million in compensatory and $24 million in punitive damages; NaphCare appealed the § 1983 verdict and punitive damages award.
- The Ninth Circuit affirmed the Monell liability verdict but found the punitive damages award excessive and remanded for reduction to a 4:1 ratio with compensatory damages.
- Judge Collins dissented, arguing insufficient evidence of a widespread, well-settled practice or deliberate indifference to support Monell liability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether sufficient evidence supported Monell liability | NaphCare’s routine use of non-medical jail staff for critical monitoring amounted to a policy causing constitutional harm | Evidence was speculative; no proof of a persistent custom causing constitutional violations | Sufficient evidence supported jury’s Monell finding |
| Whether lack of a deliberate indifference jury instruction was error | Not necessary; punitive damages finding required deliberate indifference | Lack of instruction prejudiced defense; should require new trial | No prejudice—jury necessarily found deliberate indifference |
| Whether the punitive damages award was constitutionally excessive | Award reflected jury’s finding of egregious conduct and indifference | 9.7:1 ratio (punitive:compensatory) was grossly excessive and not justified | Remanded to reduce award to no greater than 4:1 ratio |
| Sufficiency of evidence for a widespread or permanent custom (dissent) | Widespread practice demonstrated by testimony and regular procedures | No pattern of similar constitutional violations shown | Majority: Sufficient evidence; Dissent: Insufficient evidence |
Key Cases Cited
- Monell v. Dep’t of Social Servs. of City of New York, 436 U.S. 658 (municipalities liable under § 1983 only for official policy/custom)
- Castro v. County of Los Angeles, 833 F.3d 1060 (requiring proof of deliberate indifference for Monell custom claims)
- Connick v. Thompson, 563 U.S. 51 (liability under § 1983 for entity’s own illegal acts or official policy/custom only, not vicarious)
- State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (due process limits on punitive damages ratios)
- Dougherty v. City of Covina, 654 F.3d 892 (elements for Monell liability)
- Gordon v. County of Orange, 888 F.3d 1118 (medical care claims by pretrial detainees under the Fourteenth Amendment)