Nancy Morris v. Andrew Bland
666 F. App'x 233
| 4th Cir. | 2016Background
- David Woods was incarcerated at Hill-Finklea Detention Center Nov. 5–8, 2010; he exhibited shaking, disorientation, soiling, inability to take medication, and reported/observed possible blood in stool during that weekend.
- HFDC medical staff were offsite after hours; shift sergeants and correctional officers were responsible for observing inmates and contacting on-call medical personnel.
- Appellants (five HFDC employees who worked the final weekend) monitored Woods, recorded observations in logs, but did not summon timely medical care; Woods was released Nov. 8, transported to hospital with severe GI bleeding and died Nov. 11.
- Plaintiff Nancy Morris (personal representative) sued under 42 U.S.C. § 1983 for deliberate indifference (survival and wrongful death); many defendants settled or were dismissed; trial focused on Nov. 5–8 conduct by Appellants.
- Jury found deliberate indifference, awarded $500,000 compensatory (joint), and substantial punitive damages (varying by defendant); district court reduced compensatory award by setoff based on prior settlement with medical contractor; defendants appealed.
Issues
| Issue | Plaintiff's Argument (Morris) | Defendant's Argument (Appellants) | Held |
|---|---|---|---|
| Admissibility of evidence about prior treatment, settlement, alcohol/drugs, expert testimony | Prior treatment and medical history were irrelevant to Nov. 5–8 deliberate indifference claim; plaintiff sought to exclude prejudicial material | Such evidence was relevant to causation/subjective knowledge and should be admitted | District court did not abuse discretion in excluding prior-treatment/settlement and alcohol evidence; cross-examination of plaintiff's expert allowed; treating/pathologist testimony limited for lack of Rule 26 report |
| Sufficiency of evidence for deliberate indifference (Rule 50/59) | Evidence (videos, inmate and officer reports, incident report, hospital findings) shows serious need obvious to laypersons and officers had subjective knowledge | Evidence insufficient; causation speculative; errors in evidence rulings affected verdict | Viewing evidence in plaintiff's favor, reasonable jury could find objective serious need and subjective deliberate indifference; Rule 50/59 denials affirmed |
| Punitive damages — availability, excessiveness, supervisory liability | Punitive damages appropriate for reckless/callous indifference; amount justified by reprehensibility and deterrence | Not supported by evidence; awards excessive and disproportionate (esp. higher awards to shift sergeants) | Punitive damages upheld as consistent with § 1983 standards; ratios not constitutionally excessive given facts and reprehensibility; higher awards for sergeants supported by record |
| Setoff calculation for prior settlement with medical contractor | Apply South Carolina law to prevent double recovery; allocate settlement between survival and wrongful death and credit accordingly | Appellants contested allocation and percentage assigned to period of Appellants’ conduct | District court's allocation (full offset of wrongful-death share; 25% of survival share attributable to Appellants' period) was not clearly erroneous; setoff affirmed |
Key Cases Cited
- Iko v. Shreve, 535 F.3d 225 (4th Cir. 2008) (elements of deliberate indifference; serious medical need objective/subjective test)
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (deliberate indifference to serious medical needs violates Eighth Amendment)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (actual knowledge of substantial risk may be inferred from circumstantial evidence)
- Parrish ex rel. Lee v. Cleveland, 372 F.3d 294 (4th Cir. 2004) (patently inadequate response can support inference of subjective awareness)
- Cooper v. Dyke, 814 F.2d 941 (4th Cir. 1987) (punitive damages available where conduct shows reckless or callous indifference under § 1983)
- BMW of N. Am., Inc. v. Gore, 517 U.S. 559 (U.S. 1996) (guideposts for assessing excessiveness of punitive damages)
- State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (U.S. 2003) (single-digit punitive/compensatory ratios and reprehensibility analysis for due process review)