$200,000 Verdict in Shackling of Tennessee Prisoner in Labor Overturned by Sixth Circuit

The Sixth Circuit Court of Appeals has reversed the grant of summary judgment to a woman who was shackled to a hospital bed while she was in labor and postpartum. The order nullifies a $200,000 jury award in the case.

The legal victory for the Metropolitan Government of Nashville and Davidson County reopens the case brought by Juana Villegas. She was arrested on July 3, 2008, when she was unable to produce a valid driver’s license during a traffic stop. At the time of the arrest, Villegas was nine months pregnant.

Once at the jail, it was determined Villegas was in the country illegally, and an immigration detainer was placed upon her, which prevented her release until she posted bond or resolved the local charges. Unable to post bond, she was considered to be a medium-security detainee.

Late in the evening of July 5, Villegas’ water broke and she went into labor. An ambulance was called, and she was placed on a stretcher with her wrists handcuffed together in front of her body and her legs restrained together. The leg shackles were removed at the hospital only for her to change into a hospital gown. When a female guard arrived to relieve the other guards, she removed the handcuffs and restrained one of Villegas’ legs to the bed.

Approximately two hours before giving birth, the restraints were removed. Six hours after giving birth, Villegas was again restrained by an ankle to the bed; she was never handcuffed postpartum. When she left the hospital, the defendants did not allow her to take a breast pump the hospital had given her.

Villegas filed a civil suit in a Tennessee federal district court in March, 2009. That court granted her partial summary judgment on April 27, 2011, on the basis that the Defendant was deliberately indifferent to Villegas’ medical needs by shackling her while she was in labor and postpartum and denying her the breast pump on her release from the hospital. After a three-day damages trial, the jury awarded Villegas $200,000.

On appeal, the Sixth Circuit found Villegas’ claim did not quite square with its medical-needs jurisprudence. It held the claim is best analyzed under the general deliberate indifference principles.

On the objective component, the court asked whether shackling detainees in the manner and under circumstances in which Villegas was shackled creates a substantial risk of serious harm that society chooses not to tolerate. The issue hinged on if the shackling of pregnant women during labor is “violative of the contemporary standards of decency.”

The consensus of courts and a chorus of prominent organizations condemn the practice absent extenuating circumstances. Villegas’ security classification mandated the shackling, but a jury could reasonably conclude Villegas was not a flight risk.

As to the subjective component, the question was whether the officers had knowledge of the substantial risk, recognized the harm the risk could cause, and, nonetheless, disregarded it. Expert testimony was presented by both sides on this issue, which included physical and psychological harms. In the end, the Court said these are issues best left to a jury to resolve.

Finally, the Court found Villegas failed to provide sufficient evidence that denial of the breast pump presented a risk of harm. Based on all these factors, the Sixth Circuit held the district court improperly granted Villegas summary judgment, and it reversed that order and remanded for further proceedings. See: Villegas v. the Metropolitan Government of Nashville and Davidson County, Case No. 11-6031 (6^th Cir 2013).

Following remand, the parties settled the lawsuit for $490,000, inclusive of attorney fees, in October 2013. The district court also suggested that federal immigration officials grant Villegas a special visa for victims of crimes, which would allow her to remain in the U.S.

Additional source: The New York Times

Subscribe today

Already a subscriber? Login

Related legal case