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District Court in Eastern Kentucky Dismisses Case By Prisoner in Noble v. Three Forks Regional Jail Authority

February 28, 2014

Recently, in Noble v. Three Forks Regional Jail Authority, a Kentucky inmate sued the prison staff for, among other things, medical malpractice and intentional infliction of emotional distress.

breakout-740275-m.jpgArlie Noble was convicted in 2011 of possessing and distributing child pornography. Noble was sentenced and sent to the Three Forks Regional Jail until his release the following year. Noble allegedly suffered from diabetes and Crohn's disease, which required extensive treatment.

During his incarceration, Noble claimed that his rights were repeatedly violated, in that the staff gave him his diabetes medication in a manner contrary to his doctor's advice; and fed him doughnuts, honey buns, and other foods high in sugar that worsened his condition. As a result, Noble claimed to suffer from glaucoma, internal organ damage, and dysfunctional sugar levels. In claiming medical malpractice and intentional infliction of emotional distress, Noble cited state law. He sought past and future medical expenses, past and future expenses arising from emotional distress, and punitive damages. The Three Forks Regional Jail Authority filed a motion for summary judgment, arguing among other things, that Noble's state law claims were barred by sovereign immunity and otherwise failed as a matter of law.

The district court noted that Three Forks Regional Jail was established by law as a regional jail for Breathitt, Lee, Owsley, and Wolfe Counties in Kentucky. Since Kentucky has not waived its immunity against tort suits, state entities like Three Forks Regional Jail are entitled to sovereign immunity on state law claims seeking damages. Therefore, Noble's claims against the jail were dismissed.

The district court then looked at Noble's claims against the Three Forks Regional Jail staff in their individual capacities. The staff claimed to be shielded by the doctrine of qualified immunity, in that they were performing discretionary acts or functions within the scope of their authority and in good faith. Qualified immunity, when applied properly, protects all but those who are clearly incompetent or those who knowingly violate the law. The court determined that the staff provided sufficient evidence that their actions did fall within the realm of qualified immunity. The staff acted within the scope of their authority and in good faith in providing food and medicine according to the Jail's policies and specific accommodations provided to Noble.

Even if the staff did not have qualified immunity, Noble's claims would have failed on their own. Noble never put forth any evidence that the staff deviated from the appropriate standard of care. Nor did he provide evidence of the pain and suffering or emotional distress that he supposedly suffered as a result of the staff's actions. Because the Three Forks Regional Jail staff had qualified immunity, and because Noble's claims would have failed even so, the district court granted summary judgment in favor of Three Forks Regional Jail Authority, effectively dismissing the case.

Miller & Falkner is an Indiana and Kentucky plaintiffs law firm serving residents of Kentucky and Indiana. Located in Louisville, Kentucky, the firm provides representation in the areas of personal injury and employment law. If you need a Kentucky personal injury attorney, contact us today for a free consultation.

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