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 ...
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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