Woodward v. Correctional Medical Services.

U.S. Appeals Court

SUICIDE

TRAINING

DELIBERATE INDIFFERENCE

Woodward v. Correctional Medical Services, 368 F.3d 917 (7th Cir. 2004). The administratrix of the estate of a pretrial detainee who had committed suicide in a county jail brought a [section] 1983 action against a private contractor hired by the county to provide medical and mental health services at the jail, and against the contractor's agents. The district court entered judgment on a jury verdict against the contractor and the contractor's social worker, awarding $250,000 in compensatory damages and $1.5 million in punitive damages, and denied motions for summary judgment as a matter of law. The contractor appealed. The appeals court affirmed, finding that the contractor's employee's lack of training and carelessness were relevant toward establishing deliberate indifference, even though the employee herself was not found liable. The court held that the fact that no previous suicides had occurred in the jail did not preclude the contractor's liability. According to the appeals court, the district court did not abuse its discretion by letting the punitive damages award stand. The estate proffered evidence that the contractor failed to adequately train its employees and condoned employees' failure to complete mental health intake forms and the social worker's practice of challenging suicide watch referrals. According to the court, employees knew that the detainee was suicidal but failed several time to place him on suicide watch, in violation of its own written procedures. The court found that evidence of an alcohol-impaired nurse, intake backlogs, and claims of delayed or denied medical care to other inmates was relevant to the contractor's state of mind and was therefore admissible. (Lake County Jail, Illinois)