Tennessee Court of Appeals Reverses Finding of No Liability of Jailer for Failure to Provide Proper Medical Care to Inmate

The recent case of  Payne v. Tipton County gave the Tennessee Court of Appeals the opportunity to review the finding of the trial court of no liability on the part of the defendant, Tipton County, for failure to provide appropriate and timely medical care to an inmate.  The inmate suffered a severe hypertensive crisis while in custody of the county,  leading to renal failure, a stroke, heart attack, hemorrhage on his brain, anemia, seizures, kidney failure, and other conditions and resulting in a 45-day hospital admission.

The inmate appealed, and the Court of Appeals reversed the finding of the trial court. In reaching this decision, the Court of Appeals addressed what duty was owed to the inmate by Tipton County. The court noted that under Tennessee law prison officials have a duty to exercise reasonable care for the protection of those in their custody, but that they are not insurers of a prisoner’s safety. Instead, prison officials must act reasonably in light of the inmate’s known condition. The court went on to discuss the duty of a prison to provide inmates with access to proper medical treatment.

The court reviewed the evidence and testimony presented at trial and found that the County failed to provide the inmate with appropriate medical care and failed to follow its own procedures with regard to providing the inmate with medical care. Specifically, the Court of Appeals found that Tipton County breached its duty to provide proper medical treatment during the inmate’s confinement by:

(1) failing to give [the inmate] a physical within fourteen days of his confinement, as required by the [jail’s procedures]; (2) failing to consider the results of the earlier physical at anytime after [the inmate] began exhibiting symptons; (3) failing to ensure that [the inmate] was examined and diagnosed by a physician at anytime during his confinement once he began to exhibit symptoms, as required by [the jail’s] own Manual; and (4) failing to take [the inmate’s] blood pressure at anytime prior to [the date the inmate was hospitalized], despite the fact that Tipton County officers were able to perform that function.

On this basis, the Court of Appeals reversed the trial court and remanded the case for a determination of damages.