Phillip David Schaub v. Steven VonWald, No. 10-1280 (8th Cir. 2011)
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Appellee, a 21 year-old paraplegic with several serious medical conditions, sued the director of the Olmstead County Adult Detention Center ("ADC") where he was incarcerated, alleging constitutional violations under the Eighth Amendment, Monell v. Department of Social Services, and the Americans with Disabilities Act. The director appealed the district court's judgment and award of punitive damages to appellee. The court held that there was ample evidence to support the district court's findings of fact where the ADC could not accommodate appellee's known medical needs; the director knew the ADC could not accommodate appellee's known medical needs; the director misrepresented the ability of the ADC to care for appellee's needs to a judge; and the director failed to take adequate steps to provide appellee medically-necessary care or have him removed from the full-time medical care of the ADC. The court also held that the district court did not clearly err by finding that the director's deliberate indifference caused injury to appellee. The court further held that there was sufficient evidentiary basis for the district court to find that the director's behavior called for an award of punitive damages and that the district court adequately explained the appropriateness of the punitive damages.
Court Description: Civil case - civil rights. District court's findings that defendant deliberately disregarded plaintiff's serious medical needs while plaintiff was detained at the Olmstead County Adult Detention Center were supported by sufficient evidence; defendant, the director of the facility, knew there was a substantial risk to plaintiff's health if certain precautions were not taken to deal with his needs as a paraplegic and defendant wrongfully assured the sentencing judge that the facility could accommodate those needs; further, defendant took no steps to follow up on the situation after he had been personally involved in the decision- making regarding plaintiff's placement; defendant's deliberate indifference clearly exacerbated plaintiff's wounds and provided a basis for finding that defendant caused the injury; award of punitive damages was supported by evidence which showed the conduct involved callous or reckless indifference to plaintiff's medical needs; defendant failed to meet his burden to establish his personal net worth, and the district court was not required to make findings regarding defendant's financial means before awarding $750,000 in punitive damages. Judge Beam, dissenting.
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