U.S. district court: budget.

• Position: Administration

Brown v. Mitchell, 308 F.Supp.2d 682 (E.D.Va. 2004). The administratrix of an inmate's estate filed a [section] 1983 action, alleging that the inmate's death was the result of a city jail's overcrowding and jail officials' deliberate indifference to the inmate's serious medical condition. The district court granted the defendants' motion to dismiss, in part, and denied in part. The district court held that the city's purported inaction to relieve jail overcrowding could constitute an...