United States Sixth Circuit

In a 42 U.S.C. section 1983 and state law action brought by the estate of a mentally disabled inmate who died from severe dehydration, a judgment pursuant to a jury verdict in favor of the estate is affirmed in part and reversed in part where: 1) there was sufficient evidence to show deliberate indifference on the part of defendant-psychiatrist; 2) the evidence supported the compensatory and punitive damages awards; 3) the punitive damages award was not constitutionally excessive; 4) claims of evidentiary errors are rejected; 5) there was no error in applying Michigan's "high tier cap" on non-economic damages for medical malpractice; but 6) a remand was required as the district court failed to state a reason as to how it allocated the award between the statutorily capped malpractice claim and the deliberate indifference claims.

Appellate Information

• Decided 04/29/2008
• Published 04/29/2008

Judges

• Before: DAUGHTREY and SUTTON, Circuit Judges;  POLSTER, District Judge.

Court

• United States Sixth Circuit

Counsel

• For Appellees:
  
• ARGUED:  Marcy R. Matson, Hall Matson, East Lansing, Michigan, for Appellant.  Heather A. Jefferson, Fieger, Fieger, Kenney, Johnson & Giroux, Southfield, Michigan, for Appellee.   ON BRIEF:  Marcy R. Matson, Hall Matson, East Lansing, Michigan, for Appellant.  Heather A. Jefferson, Fieger, Fieger, Kenney, Johnson & Giroux, Southfield, Michigan, for Appellee.