NASHVILLE — The case of a pregnant Nashville inmate who was shackled during labor is headed back to district court to be heard by a jury.
In April 2011, U.S. District Judge William Haynes ruled in favor of Juana Villegas without a jury trial, finding that the Davidson County Sheriff’s Office violated her constitutional rights by showing indifference to her medical needs.
Villegas was arrested in July 2008 on a minor traffic violation for which charges were later dropped.
Villegas testified that her wrists and ankles were bound during an ambulance ride from the jail to the hospital. She was unshackled shortly before delivery and her baby boy was born without complications. But she was shackled again soon afterward. One leg was attached to the bed when she was lying down. Her legs were shackled together when she got up to use the bathroom.
The judge’s ruling — called a summary judgment — can only be granted in cases where the important facts are not in dispute. A jury was called in only to decide the damages award. They gave Villegas 200,000 in August 2011.
The sheriff’s office appealed.
On Monday, a three-judge panel of the 6th U.S. Circuit Court of Appeals in Cincinnati ruled 2-1 that summary judgment was inappropriate because there were disputed facts that needed to be decided by a jury.
The Appeals Court stated that “the shackling of pregnant detainees while in labor offends contemporary standards of human decency such that the practice violates the Eighth Amendment’s prohibition against the ‘unnecessary and wanton infliction of pain.’”
However, it also found that there are exceptions for when a prisoner poses a danger or a flight risk. The court concluded that whether Villegas posed a flight risk was a question for a jury. The court also pointed to differing expert testimony from doctors about whether the shackling posed a health risk for Villegas and her baby. And it questioned whether deputies should have known that shackling could pose a health risk.
Haynes’ 2011 ruling also found that the sheriff’s office was indifferent to Villegas’ medical needs when it denied her access to a breast pump after she left the hospital, and her breasts became painfully swollen and infected.
The Appeals Court ruled Monday that a jury must decide whether the need for a breast pump was an obvious medical need that deputies should have recognized.
A third judge on the Appeals Court’s panel disagreed with the majority and found that summary judgment was proper. She concluded that there was no evidence that Villegas posed a danger or a flight risk and that there was evidence that shackling posed serious health risks to Villegas and the baby.
NASHVILLE, Tenn. (AP) — The case of a pregnant Nashville inmate who was shackled during labor is going back to district court to be heard by a jury.
In April 2011, U.S. District Judge William Haynes ruled in favor of Juana Villegas without a jury trial. He found that the Davidson County Sheriff's Office violated Villegas' constitutional rights by showing indifference to her medical needs.
The judge's ruling — called a summary judgment — can only be granted in cases where the facts are not in dispute.
On Monday, a panel of the 6th U.S. Circuit Court of Appeals ruled that summary judgment was inappropriate.
Although the court stated that shackling an inmate during labor "offends contemporary standards of human decency," it said there were disputed facts that should be decided by a jury.