United States Seventh Circuit

In plaintiff's 42 U.S.C. section 1983 suit against a county, county sheriff, and correctional officers, arising from her son's death of pneumococcal meningitis less than a week later following his detention at the county jail, judgment of the district court is affirmed in part and reversed in part where: 1) district court's denial of the officers' and county's motions for judgment as a matter of law and for a new trial are affirmed as the jury had sufficient evidence to impose liability against the officers for their deliberate indifference to the detainee's medical needs and evidence was sufficient for a reasonable jury to conclude that the county had a widespread policy of disregarding detainees' medical requests; 2) however, judgment denying the sheriff's motion is reversed as there is insufficient evidence to hold the sheriff liable as the causal connection between the sheriff's policies and practices and detainee's death is tenuous in light of the jury's finding that individual correctional officers deliberately disregarded his medical needs; 3) absence of sheriff's liability does not affect the jury's compensatory damage award as the parties are jointly and severally liable for the entire award; 4) the $4 million-plus damage award for constitutional violations that resulted in death is not excessive; and 5) none of the defendants' evidentiary challenges warrant a reversal.

Appellate Information

• Argued 12/09/2008
• Decided 05/03/2010
• Published 05/03/2010

Judges

• WILLIAMS, Circuit Judge., Before FLAUM, WOOD, and WILLIAMS, Circuit Judges.

Court

• United States Seventh Circuit

Counsel

• For Appellees:
  
• Daniel S. Alexander (argued), Chicago, IL, for Plaintiff-Appellee., Andrew Creighton (argued), Chicago, IL, for Defendants-Appellants.