U.S. District Court
Brown v. Mitchell, 327 F.Supp.2d 615 (E.D.Va. 2004). The administratrix of the estate of a jail inmate who contracted and died from bacterial meningitis while in jail brought a civil rights action. The district court granted summary judgment for the defendants in part, and denied it in part. The court held that summary judgment was precluded by fact issues as to whether the city had a policy or custom of jail mismanagement, and whether any policy or custom caused the inmate's death. The court also found that there were fact issues as to whether the sheriff violated the Eighth Amendment regarding jail overcrowding. The court ordered further proceedings to determine if the city council was aware of the long history of overcrowding, poor ventilation and structural defects in the jail. The court found that the sheriff did not violate the Eighth Amendment by failing to maintain sanitation in the jail, because sanitation deficiencies were caused by overcrowding, not by...