Over-medicated 23-year old's death may be valid claim against prison doctor
Scott Quigley died in prison after he was administered three days worth of two different anti-depressant. An otherwise healthy young man suffering from moderate depression, Quigley had asked the prison doctor if he could try a different anti-depressant. The doctor prescribed Trazedone without discontinuing Quigley's Elavil. Although the prison doctor's three experts claimed that Quigley probably died from a seizure (despite the fact that he had no history of seizures, apparently), the Estate's doctors expressed the opinion that he died as a result of complications from anti-depressant overdose.
The prison officials sought summary disposition of the wrongful death claim, arguing that the doctor's error was, at worst, merely negligence for which he enjoyed immunity under state and federal law. The trial judge rejected summary disposition, holding that if the jury chose to believe the Estate's experts and concluded that the doctor carelessly exposed the young man to a known, substantial risk, he would not be entitled to immunity.
The Sixth Circuit agreed. Under the federal standard--"deliberate indifference" to the prisoner's medical needs violating the 8th Amendment--or under the state standard of "gross negligence," the Estate's experts had documented a claim. If the jury concludes that the prison doctor knew or should have known that he was exposing Quigley to an unacceptable risk of death or serious harm, and ignored that risk, the jury could rule against him under federal and state law.