Hughes v. Ohio Dept. of Rehab. & Corr., 2016 Ohio 7353

Plaintiff (inmate at Allen Oakwood Correctional Institution) was transported on April 10, 2015 to Franklin Medical Center (FMC) for an ultrasound and wore standard hub transport handcuffs during the trip.
Plaintiff testified he previously had a long-expired (1996) medical restriction for oversized/soft restraints and repeatedly told officers he needed non-standard restraints because of large wrists.
Corrections officers applied standard hub-issued restraints, checked fit by confirming a fingertip could fit between cuff and wrist, and plaintiff rode about two hours to FMC, was briefly uncuffed for the ultrasound, then re-cuffed and returned to AOCI.
After return to Oakwood, plaintiff showed abrasions, swelling and bleeding on his wrists; photographs and incident reports were prepared and nurses treated him that evening and thereafter.
Magistrate found handcuffs fit appropriately when applied, no valid contemporaneous medical restriction existed, officers followed hub policy (standard restraints unless a medical restriction), and medical care was timely; recommended judgment for defendant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were officers negligent in applying/using restraints causing injury?	Hughes: officers should have used soft/oversized restraints and/or supervisor should have intervened.	ODRC: restraints were hub-issued, fit per protocol (one-finger rule), no valid medical restriction existed; officers followed policy.	No breach — cuffs fit appropriately; injury not reasonably foreseeable; discretionary policies protected transport decisions.
Was there negligent delay or inadequacy in medical care after injury?	Hughes: medical response was delayed/inadequate, worsening injury.	ODRC: nurses examined plaintiff the evening of return, documented care, and provided follow-up; no unreasonable delay shown.	No breach — medical care was timely and appropriate; plaintiff failed to prove harm from delay.
Did defendant have duty to provide non-standard restraints absent a current medical restriction?	Hughes: prior long-ago restriction and his statements should have prompted accommodation.	ODRC: medical restrictions expire after one year and only current physician orders permit soft/oversized restraints; officers are not medical decisionmakers.	Held for defendant — no current medical restriction existed; issuance/renewal is medical responsibility.

Woods v. Ohio Dept. of Rehab. & Corr., 130 Ohio App.3d 742 (10th Dist. 1998) (plaintiff bears burden to prove negligence by preponderance of evidence)
Reynolds v. State, 14 Ohio St.3d 68 (1984) (discretionary immunity can protect state action complying with policy decisions)