Bowman v. Corrections Corp. of America.

• Position: ASSESSMENT OF COSTS

U.S. District Court

CONTRACT SERVICES

Bowman v. Corrections Corp. of America, 188 F.Supp.2d 870 (M.D.Tenn. 2000). The mother of a deceased inmate brought a [section] 1983 action against a corporation that managed a correctional facility, the warden, a hospital and physicians, alleging violations of his Eighth Amendment right to adequate medical care for sickle cell anemia. After a jury trial judgment was entered in favor of the defendants the plaintiff moved for judgment as a matter of law. The district court held that the corporation's medical policy violated contemporary standards of decency. According to the court, it was proper to consider the constitutionality of the medical policy of the corporation that managed the correctional facility, even though the mother's claims for damages against the physicians were unsuccessful, because the corporation's liability for its medical policy was measured by a different legal standard. The court concluded that the corporation would be treated as a municipal corporation for [section] 1983 liability purposes and noted that the corporation could not "contract away" its obligation to provide adequate medical care to inmates in its custody. The court held that the corporation that managed the facility violated contemporary standards of decency by contracting with a physician who provided exclusive medical services with...