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Hunt v. Ohio Department of Rehabilitation & Correction

Ohio Court of Claims
1997 Ohio Misc. LEXIS 313, 90 Ohio Misc. 2d 42, 696 N.E.2d 674 (1997)
ELI5:

Rule of Law:

The state owes a duty of reasonable care to inmates, and when an inmate is required to perform labor, this duty includes providing adequate safety training and warnings regarding the specific risks of any equipment used.


Facts:

  • Lesa Hunt was an inmate under the custody of the Ohio Department of Rehabilitation and Correction (ODRC).
  • On January 23, 1995, Corrections Officer Carl Jenkins, who had no prior experience operating a snowblower, was assigned to train Hunt on its use.
  • Officer Jenkins provided Hunt with a ten-minute training session before she was assigned to clear sidewalks with the machine.
  • While Hunt operated the snowblower, the chute became clogged with snow.
  • Hunt turned off the 'Power Take Off' (PTO) switch but did not turn off the main engine ignition switch, believing the machine was fully disengaged.
  • She then inserted her hand into the chute to clear the blockage.
  • The machine's blades, which were still spinning, caught Hunt's hand and partially severed three of her fingers.

Procedural Posture:

  • Lesa Hunt filed a complaint against the Department of Rehabilitation and Correction in the Court of Claims of Ohio, alleging negligence.
  • The court held a bench trial focused solely on the issue of liability.
  • After the court found the defendant liable, a separate trial was held on the issue of damages.

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Issue:

Did the Department of Rehabilitation and Correction breach its duty of reasonable care to an inmate by providing inadequate safety instructions and training on the operation of a snowblower?


Opinions:

Majority - Dean Strausbaugh

Yes, the Department of Rehabilitation and Correction breached its duty of reasonable care by failing to provide adequate safety training and warnings to an inmate operating dangerous machinery. The state owes prisoners a special duty of reasonable care, which, in the context of inmate labor, requires training specific to the work performed. The court found that the ten-minute training provided by an inexperienced officer was insufficient, particularly because it failed to adequately warn Hunt to turn off the engine ignition and never place her hand in the chute. The court reasoned that it is foreseeable a new user might mistakenly believe the machine was safe after only disengaging the PTO switch. However, the court also found Hunt was 40% contributorily negligent for disregarding a potential hazard and failing to use common sense.



Analysis:

This case clarifies the specific standard of care the state owes to inmate laborers, extending the general duty of reasonable care to include specific, adequate safety training for assigned tasks involving dangerous equipment. It establishes that a brief, superficial training by an inexperienced supervisor is a breach of this duty. The decision also affirms the application of comparative negligence in this context, demonstrating that an inmate's own carelessness can reduce the state's liability. This precedent reinforces that correctional facilities are liable for foreseeable injuries resulting from inadequate instruction on workplace machinery.

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