City of Louisville v Humphrey
461 S.W.2d 352 (1970)
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Rule of Law:
A municipality is not liable for injuries a prisoner sustains while in custody unless the plaintiff proves either that a municipal employee inflicted the injury or, if a fellow prisoner inflicted it, that the municipality was negligent by having prior knowledge of the fellow prisoner's violent propensities.
Facts:
- Ruel McKinley Humphrey was arrested for being highly intoxicated and was observed by arresting officers to have only a minor scratch above his eye.
- Humphrey was booked into the Louisville city jail at 2:35 a.m. and later moved by elevator to a 'drunk tank' on the third floor at 4:15 a.m.
- Jail guards testified that upon exiting the elevator, Humphrey immediately began to collapse and was then dragged to the cell.
- Testimony was conflicting as to whether another prisoner was in the 'drunk tank' with Humphrey.
- At 7:15 a.m. and again at noon, a jail guard was unable to awaken Humphrey.
- Humphrey was taken to a hospital where he was diagnosed with an unconscious-inducing subdural hematoma.
- A neurosurgeon testified that the fatal injury was likely inflicted less than 36-48 hours prior to diagnosis, placing the time of injury during Humphrey's confinement.
- Humphrey died on December 13, 1966, without ever regaining consciousness.
Procedural Posture:
- Humphrey's administratrix (appellee) sued the City of Louisville (appellant) in a Kentucky trial court.
- A jury returned a verdict in favor of the appellee for $56,534.34.
- The trial court entered a judgment on the jury's verdict.
- The City of Louisville appealed the judgment to the Court of Appeals of Kentucky.
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Issue:
Is a city liable for the death of a prisoner from injuries sustained while in custody when the plaintiff cannot produce direct evidence that city employees inflicted the injuries or that the city knew of a fellow prisoner's violent tendencies?
Opinions:
Majority - Chief Justice Edward P. Hill, Jr.
No. A city is not liable for a prisoner's death under these circumstances. The court rejected the application of res ipsa loquitur, reasoning that even if it is inferred the injury occurred in custody, the evidence leaves only speculation as to whether a city employee or a fellow prisoner was the cause. The court cannot assume either to be the case. If a fellow prisoner caused the injury, the plaintiff must prove negligence on the part of the city, which requires showing the city had prior knowledge of the violent propensities of that specific prisoner. As the plaintiff presented no such evidence, they failed to meet their burden of proof. The court declined to make the city an absolute insurer of a prisoner's safety, as that would impose an unfair burden.
Analysis:
This decision solidifies a high evidentiary bar for plaintiffs in cases involving injuries to prisoners in municipal custody. By rejecting the res ipsa loquitur doctrine in this context, the court prevents liability from being inferred solely from the fact that an injury occurred in jail. The ruling reinforces the specific negligence standard requiring proof of prior knowledge of a fellow inmate's violent tendencies, significantly limiting a city's liability for inmate-on-inmate violence. This precedent makes recovery very difficult for plaintiffs who, due to their incarceration, are often unable to gather the specific evidence required by the court.
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