Louisiana Personal Injury Lawyer Blog
Can an inmate be awarded damages from an injury caused by the employees of the correctional facility? According to the 5th Circuit Court of Appeal, the answer is yes. Mr. Miller was an inmate at Elayne Hunt Correctional Facility when an employee of the facility pulled him out of his bunk and threw him on the ground. Miller sued Captain Credit and the State of Louisiana for negligence under state law as well as violations of the 8th amendment under 42 U.S.C. §§ 1331 and 1983. Miller claimed that Captain Credit, as an employee for the state of Louisiana violated his civil rights with his act of negligence and that the federal district court has jurisdiction in this case.
When the case went to trial, a jury found that the employee acted with negligence and therefore awarded Mr. Miller damages. Captain Credit moved to alter the judgment under Fed. R. Civ. P. 56(e), arguing that Miller failed to prove a causal relationship between his shoulder injury and the negligent act. The district court denied their motion and they appealed the Fifth Circuit.
Federal Rule 59(e) gives the district court the authority to alter or amend a judgment when they have committed a “manifest error of law or fact”, and the appellate court reviews for an abuse of discretion. See Schiller v. Physicians Res. Grp., 342 F.3d 563,567 (5th Cir. 2003). For this type of appeal, the district court’s decision and the decision-making process need only be reasonable for the decision to be affirmed.
Captain Credit argued that the district court erred because there was no expert testimony to determine the extent of Miller’s injuries. Captain Credit also argued that the district court abused its discretion because it omitted discussion of legal causation. The Fifth Circuit Court of Appeal disagreed with both arguments. First, according to Louisiana state law, expert testimony is only required when the medical issue is outside common knowledge. See Cannet v. Franklynn Pest Co., 985 So.2d 270, 276 (La. Ct. App. 2008). Because Mr. Miller’s injuries were within common knowledge, expert testimony was unnecessary to determine the extent of his injuries. The court found Captain Credit’s second argument that the district court abused its discretion by omitting the discussion of legal causation inaccurate. The Fifth Circuit stated that the district court thoroughly analyzed the evidence and reasonably concluded that there was extensive testimony concerning causation and the extent of the plaintiff’s injuries. Therefore, Captain Credit’s second argument failed as well.
Causation is an essential element in negligence cases. The success of many cases hinges on whether a plaintiff can prove causation between the negligent act and the injury. Although Miller’s shoulder was previously injured, he was able to prove Captain Credit’s actions exacerbated his previously injured shoulder. This case is also important because it highlights the requirements when it comes to expert testimony. In Louisiana, expert testimony is only required when the injury falls outside the realm of common knowledge. It is important to know this requirement when preparing your case.
Additional Sources: CHRISTOPHER MILLER, v. CAPTAIN CREDIT; STATE OF LOUISIANA, Through the Department of
Public Safety and Corrections, Elayn Hunt Correctional Center
Written by Berniard Law Blog Writer: Ashley Walker
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