Schaub v. VonWald
2011 U.S. App. LEXIS 8490
| 8th Cir. | 2011Background
- Schaub, a paraplegic, was imprisoned in the Olmsted County Detention Center (ADC) where VonWald was the director.
- Schaub has serious medical needs (pressure sores, edema, spasticity) requiring regular repositioning, specialized bedding, and assistive devices.
- During confinement, Schaub was in work release; medical care depended on outside physicians, with ADC staff handling routine care only when in the ADC.
- After a leg fracture, Schaub’s condition deteriorated due to alleged inadequate ADC care (no pressure-relieving mattress, grab bars, or proper wound care).
- Judge Williamson sought to modify Schaub’s sentence for home electronic monitoring; VonWald allegedly misrepresented ADC capabilities in a May 15 letter responding to the judge.
- The district court found VonWald deliberately indifferent to Schaub’s serious medical needs and awarded compensatory and punitive damages; on appeal, the Eighth Circuit affirmed the liability and punitive award, while a dissent challenged the majority’s reasoning.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether VonWald’s conduct violated the Eighth Amendment | Schaub argues VonWald knew of and deliberately disregarded his serious medical needs | VonWald contends there was no personal knowledge or deliberate disregard and he relied on medical staff | Yes; district court’s finding of deliberate indifference upheld |
| Whether there is causation between VonWald’s conduct and Schaub’s injuries | Schaub asserts VonWald’s actions caused or significantly worsened his condition | VonWald argues causation is not clearly proven and expert causation was needed | Causation supported; district court not clearly erroneous |
| Whether punitive damages were properly awarded | Schaub asserts punitive damages were warranted for reckless indifference | VonWald argues no sufficient evidence of callous indifference or need for deterrence/punishment | Punitive damages sustained but later dissent argues the award was impermissibly excessive given record |
| Whether expert causation testimony was required | Schaub contends expert causation was not required for observable medical harms | VonWald contends expert causation was necessary due to sophisticated medical issues | No strict requirement for expert causation found; district court’s reasoning sustained (though noted by dissent) |
| Whether evidence of net worth was necessary to support punitive damages | Schaub argued for consideration of deterrence; net worth evidence not required | VonWald asserts lack of net worth evidence undermines punitive award | District court did not err in not detailing net worth; punitive award affirmed |
Key Cases Cited
- Helling v. McKinney, 509 U.S. 25 (1993) (Eighth Amendment scrutiny of prison conditions and medical care)
- Coleman v. Rahija, 114 F.3d 778 (8th Cir. 1997) (Deliberate indifference standard; higher than negligence)
- Farmer v. Brennan, 511 U.S. 825 (1994) (Knowledge of substantial risk; deliberate indifference standard)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment medical care standard for prisoners)
- Lenz v. Wade, 490 F.3d 991 (8th Cir. 2007) (Deliberate indifference may be inferred from obvious risk)
- Smith v. Wade, 461 U.S. 30 (1983) (Punitive damages in § 1983 cases; standards for malice or willful conduct)