Prison settings are a common place for negligence claims to arise. Since prisons are responsible for the individuals who are in their care, it is easier for a plaintiff to establish that the prison owed a duty to protect the plaintiff from harm. However, even when an accident or injury occurs in a prison, a plaintiff must still be able to show that the harm that occurred was foreseeable. This is because prison officials are not strictly liable for any and every bad act that may occur; they may only be held liable for those that they could have anticipated but failed to prevent. A recent case before the Court of Appeals in Tennessee illustrates these limits on accountability.
In this Tennessee personal injury case, W.C. brought claims against the State of Tennessee after he was seriously injured in a knife attack by another inmate at the West Tennessee State Penitentiary. W.C. was attacked by his cellmate, C.M., with a handmade knife. W.C. sued Tennessee for negligence, arguing that state officials should have known that C.M. was likely to injure someone because he had previously made a handmade knife at the prison and had previously been reported for dangerous activity. W.C. argued that despite such knowledge, the State failed to do anything to protect other prisoners from C.M. In response, the State denied having any knowledge of any violent tendencies by C.M. After discovery was conducted, the State moved for summary judgment on W.C.’s claims, arguing that there was no evidence of prior knowledge.
The State presented evidence that C.M. had previously received two separate security assessments, had no apparent history of violent charges, and wasn’t considered to be a security threat. W.C. and C.M. had been cellmates for almost three months and had no issues. They got along well, and W.C. never reported any threats from C.M. nor any fears of C.M. hurting him. Indeed, prior to the assault, W.C. stated that he did not feel at all threatened by C.M. Based on this evidence, the Tennessee Claims Commission granted the State’s motion for summary judgment. W.C. appealed.
On appeal, W.C. argued that there were genuine material facts concerning whether the State knew or had reason to know that C.M. was a danger. In Tennessee, prisons do have a duty to use reasonable and ordinary care to prevent foreseeable attacks by one inmate against another. A prison violates this duty when it knows of or had reason to know of an attack but did not take reasonable care to prevent it. W.C. argued that since C.M. had previously been caught for theft in attempting to steal metal from the prison, presumably for a knife, the prison did know that C.M. was a threat who was likely to attack another inmate, and it did not act reasonably to prevent it. The State responded that to the extent that C.M. was going to use the metal to create a knife, it stopped C.M. from doing so and punished him for the theft. It further argued that such an incident was too remote and unrelated to have put the State on notice that C.M. was likely to hurt someone.
The Court of Appeals agreed. It held that the evidence provided suggested that the State had no prior reason to think that C.M. was a security threat and that W.C. himself had felt comfortable around C.M. until the assault. It further held that the fact that C.M. had previously attempted to steal metal for an unclear purpose was not sufficiently foreseeable to impose liability under Tennessee law. The Court of Appeals affirmed the lower court and upheld the grant of summary judgment.
Prisons can be exceptionally dangerous places to be, and incidents of violence and abuse in prisons are well-documented. But this does not mean that prisons and prison officials are automatically responsible for an injury that may occur in a prison setting. An experienced advocate like Tennessee personal injury attorney Eric Beasley can help you evaluate whether the violence you experienced in prison was foreseeable and whether officials failed to take the necessary action. For more information on seeking redress and compensation for your injuries, contact the Law Office of Eric Beasley today at 615-859-2223.
Related Blog Posts:
Tennessee Court Upholds Conclusion That Officer Was Not Responsible For Accident, Tennessee Personal Injury Blog, July 7, 2017.
Tennessee Court Upholds Exclusion of Evidence for Lack of Relevance, Tennessee Personal Injury Blog, May 2, 2017.
The Complexities of Bringing Personal Injury Claims Against Large Corporations in Tennessee, Tennessee Personal Injury Blog, March 10, 2016