Thomas v. Cook County Sheriff's Dep't., No. 08-2232
In plaintiff's 42 U.S.C. section 1983 suit against a county, sheriff, and correctional employees, alleging that defendants violated her son's constitutional rights by failing to respond to his serious medical needs while detained, jury verdict in favor of the plaintiff and award in the amount of $4,450,000 is affirmed for the most part where: 1) the jury had sufficient evidence to impose liability against the county and officers for their deliberate indifference to the detainee's medical needs; 2) 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 the detainee's medical needs; 3) nonetheless, the sheriff's absence as a liable party does not affect the jury's compensatory damage award as the parties are jointly and severally liable for the entire award, which measures the amount required to compensate the plaintiff for her indivisible harm, and the sheriff only added an additional source from whom the plaintiff could collect; 4) jury's damage award for constitutional violations that resulted in death is not excessive; and 5) none of the defendants' evidentiary challenges warrant reversal.
Appeal from the United States District Court for the Northern District of Illinois, Eastern Division
Decided December 1, 2009
Opinion by Williams, Judge
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