A case addressing "deliberate indifference" to an inmate's needs

  In Gibson v. Moskowitz, M.D., the Sixth Circuit upheld a verdict for the family of an inmate who died after being neglected in jail for several days.

  The Sixth Circuit appellate panel upheld a jury verdict including compensatory and punitive damages, after a mentally disabled inmate, Ozy Vaughn, died from severe dehydration in an over-heated observation room.  The doctor who managed Vaughn's medications was aware that Vaughn's medication to treat schizophrenia interfered with his body's ability to regulate body temperature, but did not remove him from that environment on Friday.  Even though the observation room at Riverside Correctional Facility in Ionia, Michigan, reached temperatures as high as 96 and remained in the 90s [during January] all weekend, and even though Vaughn vomited after attempting to drink water from the sink, the Defendant psychiatrist did not think his condition was "life-threatening" on Monday and made no changes in Vaughn's status. Vaughn suffered from the dry heaves all that night and died of dehydration the following morning.

A jury concluded that the doctor's conduct was medical malpractice and that it also constituted a "deliberate indifference" to Vaughn's well-being, and therefore constituted a section 1983 violation of Vaughn's civil rights.  Because of the latter finding, the family was also awarded punitive damages.