Feathers v. Ohio Dept. Rehab. & Corr.
2017 Ohio 8179
Ohio Ct. App.2017Background
- Plaintiff David Feathers, an inmate in segregation at Grafton Correctional Institution, fell on stairs in April 2014 while restrained with handcuffs and a belly band and wearing shower shoes; he alleged appellee’s staff required him to ascend stairs without escort, causing head and bodily injuries.
- Feathers claimed staff violated Post Order (J)(4) (requiring handcuffing/belly chaining and escort after recreation) and that the restraints were too tight and no assistance was offered.
- At bench trial before a magistrate, Feathers testified about the fall; corrections officer testimony was general and lacked recollection of the event; documentary evidence included an electronic log entry and an inspector’s report.
- The magistrate found Post Order (J)(4) did not apply (concluding Feathers was not returning from recreation), that the stairs had no defect, Feathers could have used the handrail, and appellee did not breach its duty of care; magistrate also found Feathers’ own negligence proximately caused the fall.
- The Court of Claims overruled Feathers’ objections and adopted the magistrate’s decision; Feathers appealed to the Tenth District Court of Appeals, which affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a violation of the agency Post Order (J)(4) (escort after recreation) is evidence of breach of ordinary care | Feathers: Post Order required escort; violation shows lack of ordinary care and caused his fall | ODRC: Post Order did not apply because Feathers was not returning from recreation; the order is a security measure, not a safety guarantee | Mooted by finding Feathers was not returning from recreation; court upheld magistrate’s finding that order did not apply |
| Whether Feathers was returning from recreation when he fell | Feathers: Logbook and inspector’s report show he was returning from recreation | ODRC: Feathers’ trial testimony indicated he had been removed from his cell and had been on lower tier ~10 minutes; log entries conflicted with testimony | Court found some evidence on both sides; magistrate’s credibility determination that he was not returning from recreation was not against manifest weight of evidence |
| Whether ODRC breached its duty of reasonable care to Feathers while he was restrained | Feathers: Requiring an escorted ascent while belly-chained and handcuffed made a fall foreseeable; restraints were too tight and staff failed to protect him | ODRC: Stairs were safe, handrails were available, Feathers admitted he held the rail and had previously navigated stairs; no supervision breach shown | Court held competent, credible evidence supported finding of no breach; decision not against manifest weight of evidence |
| Whether Feathers’ contributory negligence bars recovery | Feathers: He did not voluntarily assume risk; restraints and shower shoes impeded safety | ODRC: Feathers failed to exercise reasonable personal care (e.g., use handrail, wear proper footwear) | Mooted because court found no breach by ODRC; lower-court finding of contributory negligence not necessary to resolve but was supported by record |
Key Cases Cited
- Woods v. Ohio Dept. of Rehab. & Corr., 130 Ohio App.3d 742 (10th Dist. 1998) (failure to provide safety restraints in a van can be a breach when prisoner is restrained and foreseeable risk exists)
- Cantwell Mach. Co. v. Chicago Mach. Co., 184 Ohio App.3d 287 (10th Dist. 2009) (standard for reversing on manifest weight: defer to trial court credibility findings; reversal only when verdict is manifestly contrary to reasonable inferences)
- Jacobs v. Benedict, 39 Ohio App.2d 141 (1st Dist. 1973) (discussing standard for manifest weight review)
- Royer v. Bd. of Edn. of C.R. Coblentz Local School Dist., 51 Ohio App.2d 17 (12th Dist. 1977) (same; cited for manifest weight standard)