University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Bowman v. Corrections Corporation of America PC-TN-0005
Docket / Court 96-1142 ( M.D. Tenn. )
State/Territory Tennessee
Case Type(s) Prison Conditions
Case Summary
On December 16, 1996, the Patricia Bowman, the mother of a deceased prisoner named Anthony Bowman, filed a lawsuit on behalf of Anthony's two children under 42 U.S.C. §1983 against the Corrections Corporation of America (CCA) and the Tennessee Department of Corrections in the U.S. District ... read more >
On December 16, 1996, the Patricia Bowman, the mother of a deceased prisoner named Anthony Bowman, filed a lawsuit on behalf of Anthony's two children under 42 U.S.C. §1983 against the Corrections Corporation of America (CCA) and the Tennessee Department of Corrections in the U.S. District Court for the Middle District of Tennessee. Patricia asked the court for declaratory relief, injunctive relief and damages, arguing that the defendants had violated her son's constitutional right to adequate medical care while incarcerated.

CCA was a private company employed by the Tennessee Department of Corrections to run the South Central Correctional Center, where Anthony had been housed. Over the course of his incarceration, Anthony had a long history of medical problems and hospitalizations associated with sickle cell anemia. On January 4, 1996, the prison doctor diagnosed Anthony with "an early pneumonia" and transferred him to the Nashville Memorial Hospital, where he died the next day.

The case went to trial in the district court, where the jury found that the defendants had not acted with deliberate indifference towards Anthony's serious medical condition. On June 21, 2000, the U.S. District Court for the Middle District of Tennessee (Judge William Haynes, Jr.) entered judgment in accordance with the jury's verdict, but granted Bowman's motion for declaratory judgment in part, holding that CCA's medical policies were unconstitutional because they created incentives for withholding medical care from inmates. The court enjoined CCA from enforcing its contract with the prison doctors and granted the plaintiff's motion for some of her attorneys' fees. Bowman v. Corrections Corporation of America, 188 F.Supp.2d 870 (M.D.Tenn. 2000). Both parties appealed.

On November 21, 2003, the U.S. Court of Appeals for the Sixth Circuit (Judge Danny Boggs, Judge Richard Suhrheinrich, and Judge Eugene Siler) affirmed the district court's denial of the plaintiff's motion for judgment as a matter of law, holding that there was sufficient evidence to support the jury's verdict and that the district court did not abuse its discretion. The Sixth Circuit then reversed the district court's holding with respect to the unconstitutionality of CCA's medical policy and the injunction awarded on that basis, holding that the issue was moot as to Bowman because she had no standing upon which to bring such a claim for prospective relief. Finally, the Sixth Circuit vacated the district court's award of attorneys' fees to Bowman, holding the award to be inappropriate since Bowman was no longer the prevailing party, and closed the case. Bowman v. Corrections Corporation of America, 350 F.3d 537 (6th Cir. 2003).

Kristen Sagar - 05/04/2006


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Issues and Causes of Action
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Issues
Affected Gender
Male
General
Personal injury
Medical/Mental Health
Medical care, general
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Non-government for profit
Causes of Action 42 U.S.C. § 1983
Defendant(s) Corrections Corporation of America
HTI Memorial Hospital Corporation
Prison Realty Corporation
Plaintiff Description Mother of deceased prisoner, on behalf of prisoner and his two children, alleged that the private company that managed prison violated prisoner's Eighth Amendment right to adequate medical care.
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer No
Nature of Relief None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year 2003
Case Ongoing No
Additional Resources
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Case Studies Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
By: Margo Schlanger (Washington University)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
96-1142 (M.D. Tenn.) 12/22/2003
PC-TN-0005-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Memorandum 06/21/2000 (188 F.Supp.2d 870) (M.D. Tenn.)
PC-TN-0005-0002 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion 11/21/2003 (350 F.3d 537)
PC-TN-0005-0003 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Boggs, Danny Julian (Sixth Circuit)
PC-TN-0005-0003
Haynes, William Joseph Jr. (M.D. Tenn.) [Magistrate]
PC-TN-0005-0002 | PC-TN-0005-9000
Monitors/Masters None on record
Plaintiff's Lawyers Chandler, John W. Jr. (Tennessee)
PC-TN-0005-0002 | PC-TN-0005-0003 | PC-TN-0005-9000
Johnston, Joseph Howell (Tennessee)
PC-TN-0005-0002 | PC-TN-0005-0003 | PC-TN-0005-9000
Defendant's Lawyers Anderson, Tom (Tennessee)
PC-TN-0005-0002 | PC-TN-0005-0003 | PC-TN-0005-9000
Blumstein, Andree Sophia (Tennessee)
PC-TN-0005-0003 | PC-TN-0005-9000
Blumstein, James F. (Tennessee)
PC-TN-0005-0003
Dean, George W. (Florida)
PC-TN-0005-9000
Leathers, Raymond Swen (Tennessee)
PC-TN-0005-9000
Ruth, Patrick Alan (Tennessee)
PC-TN-0005-0002 | PC-TN-0005-0003 | PC-TN-0005-9000
Stanfill, Frankie (Tennessee)
PC-TN-0005-9000
Willis, W. Reese III (Tennessee)
PC-TN-0005-9000
Other Lawyers None on record

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