City of Louisville v. Humphrey

Brief Fact Summary.

A Kentucky Court of Appeals held that a prison guard cannot be liable for a res ipsa loquitur negligence claim solely on the basis of an inmate being injured in prison because a prison guard is not an insurer of a prisoner’s safety. 

Synopsis of Rule of Law.

A prison guard is not liable for an inmate’s injury that happened in prison solely on a res ipsa loquitur negligence claim. 

Facts.

After being arrested and taken in to custody by the city of Louisville for being heavily intoxicated and shaking people’s doors, Humphrey (Plaintiff) while being  transferred to the third floor collapsed in the elevator and was dragged into the drunk tank where he was left lying on the floor. After two unsuccessful attempts to wake up Humphrey hours apart, Humphrey was taken to a local hospital where he was diagnosed with a subdural hematoma from injuries to his left eye and forehead. Humphrey was admitted into surgery where he later died from complications. His wife brought suit against the city of Louisville under a theory of res ipsa loquitur because she failed to submit direct evidence of negligence. At trial the jury ruled in favor of Humphrey but the City of Louisville appealed.

Issue.

Whether a prison guard is liable for the injury of an inmate that occurred in prison under a theory of res ipsa loquitur negligence?

Held.

No. The court determined that the prison guard is not an responsible for the prisoner’s safety. A prison guard is not liable to exercise an increased standard of care but instead is only liable for ordinary care when the inmate is intoxicated. Furthermore, the plaintiff failed to provide any evidence that the prison guard was negligent. Trial court is reversed. 

Discussion.

The court determines that even if there was negligence, it would be unclear as to what caused the injury. In prison, the injury could have been caused by a prisoner or a prison guard. Therefore, it is wrong to speculate that the prison guard caused the injury when it is plausible that a prisoner could have caused the injury.