John Payne as next of kin on behalf of the legal minor heirs of Marcus K. Payne v. Tipton County, Tennessee
448 S.W.3d 891
| Tenn. Ct. App. | 2014Background
- Marcus K. Payne was jailed in Tipton County on March 1, 2004; jail policy and Tennessee minimum standards required a more complete medical exam within 14 days of booking.
- Payne had a July 31, 2003 jail physical showing very high blood pressures (184/122 and 168/118) with the notation "HTN" but no medication prescribed.
- Tipton County staff did not give Payne a complete physical within 14 days of his March 2004 booking (the jail operated under an unwritten practice of waiving repeat physicals within one year).
- Beginning April 22, 2004 Payne complained of headaches (and later nausea, blurred vision); sick-call and medication records are inconsistent and there is no reliable evidence a physician performed a face-to-face exam or took his blood pressure before April 30.
- On April 30 Payne’s blood pressure was 169/91; he was sent to an ER, seized, and suffered stroke/renal failure and other severe injuries.
- Payne sued Tipton County for negligence; the trial court found no breach, but the Court of Appeals reversed, holding the evidence preponderated that Tipton County breached its duty and remanding for damages.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Tipton County breached its duty to provide adequate medical care to an inmate | Tipton County failed to follow minimum standards (no 14-day physical), did not consider prior elevated BPs, did not ensure physician examined or diagnose Payne, and failed to obtain BP readings earlier — causing his injuries | Jail provided access to care: Payne was seen by physician (April 26), jail followed policies, and duty to inmates is limited | Court held Tipton County breached its duty: failed to perform 14-day exam, failed to consider prior exam, failed to ensure physician exam/diagnosis, and failed to take BP before crisis — evidence preponderates against trial court finding of no breach |
| Whether jail staff provided "access" to appropriate medical treatment | Payne: access requires face-to-face physician examination and appropriate triage (including BP checks) given symptoms | Tipton County: allowing sick-call/physician prescription and following procedures satisfied access requirement | Held that mere paperwork/prescription without an examination or BP checks did not satisfy required access; Dr. Sobel’s uncontroverted opinion established breach |
| Whether the jail’s unwritten practice of waiving complete physicals conflicted with state minimum standards | Payne: unwritten waiver cannot override Tennessee Corrections Institute Minimum Standards requiring a 14-day exam | Tipton County: asserted practice and claimed it followed its procedures | Held the unwritten practice conflicted with and failed to meet the Minimum Standards; Tipton County violated the standards by not performing the 14-day exam |
| Causation — did breach cause Payne’s injuries | Payne: earlier detection/treatment of severe hypertension would likely have improved outcomes; delay was proximate cause | Tipton County: disputed causal link and relied on other factors (e.g., drug use); no expert to rebut | Held plaintiff’s expert testimony (unrebutted) established causation in fact and proximate cause; remand for damages |
Key Cases Cited
- Giggers v. Memphis Hous. Auth., 277 S.W.3d 359 (Tenn. 2009) (elements of negligence)
- King v. Anderson County, 419 S.W.3d 232 (Tenn. 2013) (negligence and causation standards)
- McClung v. Delta Square Ltd. P’ship, 937 S.W.2d 891 (Tenn. 1996) (reasonable care measured by circumstances and risk)
- Cockrum v. State, 843 S.W.2d 433 (Tenn. Ct. App. 1992) (prison officials’ duty to exercise ordinary and reasonable care for persons in custody)
- Blair v. Brownson, 197 S.W.3d 681 (Tenn. 2006) (standard of review: no presumption of correctness for conclusions of law)