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Pittmann v. County of Madison

United States District Court, S.D. Illinois

September 12, 2019

COUNTY OF MADISON, et al., Defendants.


          Staci M. Yandle United States District Judge

         Pending before the Court is Plaintiff's Motion for New Trial (Doc. 287). For the following reasons, the Motion is DENIED.


         Plaintiff Reginald Pittman was booked into the Madison County Jail on August 16, 2007. Defendants Sergeant Randy Eaton and Officer Matt Werner were employees of the Madison County Jail during Pittman's detention. On December 19, 2007, after being detained for more than four months, Pittman attempted suicide by hanging himself with a bed sheet in his jail cell. As a result of his suicide attempt, Pittman suffered ischemic anoxic injury to his brain rendering him severely brain damaged and legally disabled.

         In October 2018, a 5-day trial was held to determine whether the conduct of Defendants Eaton and/or Werner was deliberately indifferent under federal law or willful or wanton under Illinois law. The jury found for Defendants and against Plaintiff. Plaintiff now seeks a new trial asserting: 1) erroneous jury instructions; 2) erroneous evidentiary rulings; and 3) that the conduct of Pittman's Guardian prejudiced the Plaintiff.


         Jury Instructions

          When a motion for a new trial is based on a challenge to jury instructions, the trial court's jury instructions are analyzed as a whole to determine if they accurately stated the law and did not confuse the jury. Knox v. Indiana, 93 f.3d 1327. 1332 (7th Cir. 1996). If the jury instructions contain incorrect or confusing legal statements, the Court must determine whether a party was prejudiced by the instructions. United Airlines, Inc. v. United States, 111 F.3d 551, 555 (7th Cir.1997). The submission of inadequate jury instructions requires reversal only if it appears that the jury's comprehension of the issues was so misguided that one of the parties was prejudiced. Soller v. Moore, 84 F.3d 964, 969 (7th Cir.1996).

         Pursuant to F.R.C.P. 51, a party wishing to contest a jury instruction must distinctly state “the matter objected to and the grounds for the objection.” Fed.R.Civ.P. 51(c)(1). “The objection must be specific enough that the nature of the error is brought into focus.... There are no formal requirements, but pragmatically speaking the district court must be made aware of the error prior to instructing the jury, so that the judge can fix the problem before the case goes to the jury.” Schobert v. Ill. Dep't of Transp., 304 F.3d 725, 729-30 (7th Cir.2002) (citation omitted). Moreover, “…the party must state the same grounds when objecting to the jury instruction as it does in its motion for a new trial or on appeal.” Id. at 730.

         Notwithstanding Defendants' argument to the contrary, Plaintiff preserved his objection to the issues instruction given by the Court. While it is arguable that Plaintiff's Counsel initially consented to the instruction (Doc. 295, Tr. Tran. Day 4, 357:1-12), he did make a record of his position that the instruction was inconsistent with Miranda v. County of Lake, 900 F.3d 335 (7th Cir. 2018) and therefore erroneous, prior to the Court instruction the jury (Doc. 296, Tr. Tran. Day 5, 370:13-371:21). That said, Plaintiff's contention that the jury instruction given required a finding of subjective intent which was rejected by the Seventh Circuit in Miranda is simply incorrect.

         Because Pittman was a pretrial detainee, Plaintiff's claim arises under the Fourteenth Amendment's Due Process Clause, rather than the Eighth Amendment's Cruel and Unusual Punishment Clause. See, Kingsley v. Hendrickson, 135 S.Ct. 2466, 192 L.Ed.2d 416 (2015); Miranda v. County of Lake, 900 F.3d 335, 350-351 (7th Cir. 2018). Under Kingsley and Miranda, in order to prove a failure to protect claim, a plaintiff need only establish that the defendant's conduct was objectively unreasonable - not that the defendant was subjectively aware that it was unreasonable. Miranda, 900 F.3d at 352-53. In other words, a plaintiff must show that a defendant “knew, or should have known, that [a] condition posed an excessive risk to health or safety” of the detainee and “failed to act with reasonable care to mitigate the risk.” Id. This is a more exacting standard than that required to prove negligence, or even gross negligence and is “akin to reckless disregard.” Id.

         The Court submitted the following issues instruction to the jury:

The Constitution requires jail officials to protect detainees from harming themselves under certain circumstances. To succeed on this claim, Plaintiff must prove each of the following four (4) things by a preponderance of the evidence:
1. There was a strong likelihood that Plaintiff would seriously harm himself. A mere possibility of serious harm is ...

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