Warden’s Decision to Quarantine Handicapped Person in Unaccommodated Cell Actionable; $200,000 Settlement
The Sixth Circuit Court of Appeals held that a warden who placed a double amputee prisoner with MRSA in a segregation unit without handicap accommodations was not entitled to qualified immunity.
When Martinique Stoudemire, 23 at the time, entered the Michigan Department of Corrections in 2002, she had a long and well-documented history of health problems. She had numerous ailments that, without proper care, “bore a significant risk of experiencing kidney and liver damage, heart attacks, amputations, and chronic pain.”
While at the Huron Valley Women’s Facility, Stoudemire’s health quickly deteriorated. Over the five years she spent at the prison she suffered a heart attack, liver failure and a number of life-threatening embolisms. She underwent three amputations, eventually losing both legs below the knee.
Stoudemire claimed her health complications were due to inadequate care by prison medical staff. At issue on appeal was her claim against Warden Susan Davis, who retired in 2008, a year after Stoudemire was released. The claim against Davis involved her decision to quarantine Stoudemire in the prison’s segregation unit after she contracted MRSA following her final amputation surgery in December 2006.
While in segregation, Stoudemire “was never provided any assistive devices that might have allowed her to safely move between her bed, wheelchair, toilet and shower. There was no call button, so Stoudemire had to shout when she needed assistance. She alleged that the medical staff treated her with contempt; they accused her of malingering and responded with hostility whenever she sought assistance, the district court wrote in its order denying qualified immunity to Davis. “As a result, Stoudemire was left to care for herself. She was forced to crawl from her bed to the toilet. On one occasion, she had to urinate in a bowl. On another occasion, she defecated on herself.”
Stoudemire’s hygiene was neglected and she was provided only one shower while in segregation. Moreover, she “was required to dress her wounds herself, which put her at risk of infection.”
Warden Davis argued that she relied on the facility’s medical staff to provide adequate care. “This argument begs the question of what Davis needed to be told in order to comprehend the substantial risk to Stoudemire,” the Sixth Circuit wrote. “In today’s society, handicap facilities, particularly bathroom accommodations, are considered ‘the minimal civilized measure of life’s necessities.’”
“Davis’s attempt to hide behind the health care staff is unavailing because she was responsible for the placement [in segregation] and she was personally aware of Stoudemire’s condition,” the appellate court concluded, holding that a jury could find Davis liable. The district court’s denial of qualified immunity was affirmed. See: Stoudemire v. Michigan Department of Corrections, 614 Fed.Appx. 798 (6th Cir. 2015).
In a previous ruling in the same case, the Sixth Circuit found a prison guard at the Huron Valley Women’s Facility was not entitled to qualified immunity for conducting a harassing strip search of Stoudemire. [See: PLN, April 2014, p.42].
Following remand, the case went to a jury trial beginning in March 2016 but settled on April 12 before a verdict was entered. The state prison defendants agreed to pay $200,000 for Eighth Amendment and ADA violations for placing Stoudemire in segregation when she had MRSA and for the strip search. Corizon, the prison’s private medical contractor, also agreed to settle the claims against it.
“I now really understand how admirable those prisoners and former prisoners are who stick out the fight, knowing the odds against them in court, and that a court verdict can never give back what was taken from them, as well as the skill and resourcefulness of the handful of lawyers who manage to beat the odds and get large verdicts against these corporate criminals,” said Elizabeth Alexander, one of the attorneys who represented Stoudemire, who was also represented by Michigan attorney Patricia Streeter. See: Stoudemire v. Michigan Department of Corrections, U.S.D.C. (E.D. Mich.), Case No. 2:07-cv-15387-AJT-PJK.
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Related legal cases
Stoudemire v. Michigan Department of Corrections
| Year | 2015 |
|---|---|
| Cite | 614 Fed.Appx. 798 (6th Cir. 2015). |
| Level | Court of Appeals |
| Conclusion | Settlement |
| Damages | 200,000 |
| Injunction Status | N/A |
Stoudemire v. Michigan Department of Corrections
| Year | 2007 |
|---|---|
| Cite | U.S.D.C. (E.D. Mich.), Case No. 2:07-cv-15387-AJT-PJK. |
| Level | District Court |
| Conclusion | Bench Verdict |
| Injunction Status | N/A |