Letterman v. Lammers, No. 16-1410 (8th Cir. 2017)
Annotate this CasePlaintiffs filed suit against department of correction officers under 42 U.S.C. 1983 after their son died while in custody. In this appeal, defendants challenged a jury verdict in favor of plaintiffs. The Eighth Circuit affirmed the district court's denial of judgment as a matter of law, holding that the evidence was sufficient to support a reasonable inference sustaining the award of damages for pain and suffering. The court affirmed the denial of plaintiffs' motion for a new trial, holding that the close-observation policy in this case was ministerial and defendants were not entitled to official immunity; evidence of what medical staff thought but did not disclose was irrelevant and inadmissable; and defendants waived further evidentiary arguments.
Court Description: Gruender, Author, with Murphy and Kelly, Circuit Judges] Civil case - Civil rights. For the court's prior opinion affirming in part the district court's denial of defendants' motion for summary judgment in this action arising out of the death of plaintiffs' son at the Western Reception, Diagnostic and Correctional Center of the Missouri Department of Corrections, see Letterman v. Does, 789 F.3d 856 (8th Cir. 2015). Evidence was sufficient to support an award of damages for pain and suffering; the act of reporting a medical emergency when a response is not received from a prisoner was not discretionary under the facility's close-observation policy, and the defendants were not entitled to official immunity; the district court did not err in excluding evidence that the medical staff at the prison were unconcerned with the decedent's unresponsiveness after he fell and hit his head because they thought he was sleeping; evidence of what the staff thought but did not disclose is irrelevant and inadmissible; defendants have waived their challenge to certain evidentiary issues by failing to provide any reason why the district court abused its discretion in excluding the evidence under Rule 403.
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