The Kentucky Court of Appeals has issued a ruling in a negligence case involving the death of inmate Steven Lee McStoots. The court’s decision affects the estate of McStoots and the correctional staff involved in his care. The case highlights the responsibilities of correctional facilities when dealing with inmates suffering from mental health issues.

In this case, Brent Caldwell, the administrator of McStoots' estate, appealed a lower court's decision that granted summary judgment to several defendants, including correctional staff and medical professionals. The court's ruling is significant as it addresses the standards of care owed to inmates and the legal protections available to public officials.

The dispute began when Dorothy Canary, McStoots' mother, filed a wrongful death lawsuit in 2014 after her son died while incarcerated at the Kentucky State Reformatory. McStoots had a history of mental health issues, including psychosis and depression. On January 16, 2013, he died after being placed in a five-point restraint during a psychotic episode. Following Canary’s death, Caldwell took over the case, continuing the claims against the correctional staff and medical professionals involved.

The defendants in the case include Clark Taylor, the warden; Danny Perry, the unit administrator; Dr. Donna T. Smith; and CorrectCare-Integrated Health, Inc., the medical provider for the facility. The case reached the Court of Appeals after the lower court granted summary judgment in favor of all defendants, ruling that they were entitled to qualified immunity for their actions.

The Court of Appeals, led by Judge McNeill, affirmed some parts of the lower court's decision while reversing others. The court ruled that Warden Taylor and Perry were entitled to qualified immunity regarding their discretionary functions. The court stated, "The decision to employ five-point restraints, as well as duration and escalation judgments, were discretionary acts within the scope of the Appellees’ employment." Therefore, the court found that the Estate did not present sufficient evidence to show that these officials acted in bad faith.

However, the court also identified certain ministerial duties that were not fulfilled by the defendants. Specifically, the court noted that the approval required from a medical or mental health professional before placing an inmate in a five-point restraint was not obtained. The court reversed the lower court's decision on this point, stating, "Accordingly, as to the specific provision CPP 9.1(II)(G)(1)(h), we reverse and remand this case to the trial court for a jury determination on breach, causation, and damages." This means that a jury will now decide whether the failure to obtain the necessary approval contributed to McStoots' death.

The court also addressed the training of staff in the use of the five-point restraint. The ruling indicated that some staff members involved were not properly trained, which constitutes a breach of their ministerial duties. The court stated, "This ministerial duty to train under CPP 9.1(II)(A)(5) was breached by Appellees’ own admission." This aspect of the ruling allows for further examination of the training protocols in place at the correctional facility.

Additionally, the court found that Dr. Smith and CorrectCare, being private entities, were not entitled to the same qualified immunity protections as the public officials. The court noted that traditional negligence principles apply to these parties. The court stated, "Put simply, the evidence of record, including Dr. Sobel’s testimony and report, permits a jury question on the remaining elements of negligence." This means that the case against Dr. Smith and CorrectCare will continue, allowing for a jury to determine whether they acted negligently in their care of McStoots.

The impact of this ruling is significant for the future of negligence claims against correctional facilities and their staff. It emphasizes the importance of adhering to established protocols, especially when dealing with vulnerable populations such as inmates with mental health issues. The case sets a precedent for how courts may handle similar negligence claims in the future, particularly regarding the responsibilities of correctional staff and medical professionals.

Looking ahead, the case will return to the lower court for further proceedings. The trial court will need to address the jury's determination of breach, causation, and damages related to the ministerial duties identified in the appellate ruling. The Estate's claims against Dr. Smith and CorrectCare will also proceed under traditional negligence principles. The court's decision leaves open the possibility for further appeals, depending on the outcomes of the upcoming proceedings.