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Tennessee County Not Required to Pay for Medical Costs after Prisoner’s Release

Tennessee County Not Required to Pay for Medical Costs after Prisoner’s Release

by David Reutter

The Tennessee Court of Appeals has held that a prisoner does not have a private right of action for being released early from jail, in a case in which a prisoner alleged he was freed so the jail could avoid paying for his medical care.

Stanley Walker was taken into custody on April 28, 2009 after reporting to his probation officer, who determined he had failed to comply with his probation terms. A court later sentenced him to 30 days in jail “to be counted day for day.”

On May 20, 2009, Walker reported a medical condition to staff at the Bradley County Jail. He was diagnosed with a staph infection and placed in isolation. A memo was issued detailing the cost of treating Walker, and based on that cost he was freed on May 22.

Walker went to a hospital for medical treatment following his release. He sued Bradley County in August 2011, alleging he had been released early so the jail could avoid the cost of his medical care.

The trial court granted Bradley County’s motion to strike and dismiss the claims based on Walker’s contention that he was released early.

The Court of Appeals found Walker did not present a legally redressable injury by being freed before completing his jail sentence. While “non-judicial officials may not unilaterally decide to shorten validly court-entered sentences,” a prisoner “is not the proper party to bring an action to address the improper early release because it is no injury to the inmate simply to be freed from jail early.”

The appellate court further held that since Walker was not in jail when he received his medical treatment, Bradley County had no duty to pay for that care. The trial court’s order was affirmed. See: Walker v. Bradley County Government, 2014 Tenn. App. LEXIS 204 (Tenn.Ct.App. Apr. 15, 2014).


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Related legal case

Walker v. Bradley County Government