Raybin & Weissman

Federal Appeals Court Overturns Ruling for Shackled Pregnant Inmate in Villegas Case

Today, the Sixth Circuit Court of Appeals overruled an award of $200,000 to a pregnant inmate who was shackled immediately before and after giving birth.  Villegas v. Metro. Gov’t of Nashville, -F.3d-, No. 11-6031 (6th Cir. March 4, 2013).  The appeals court simply decided that the case should have been decided by a jury rather than a judge.  Thus, the claim remains intact and will likely continue following a remand back to the trial court.

Juana Villegas was arrested for driving without a valid license and, once in jail, was determined to be an undocumented immigrant.  As a result, she was classified as a “medium-security inmate.”  A few days later, while still in jail, she began to deliver her child and was transported to a hospital in shackles.  The shackles were removed while she gave birth, but she was restrained to the bed thereafter.

In 2011, Federal District Judge William Haynes, Jr. granted summary judgment to Villegas for her claim that—as a matter of law—the jail guards were “deliberately indifferent” to her medical needs by shackling her.  After a three day trial on damages, a jury awarded her $200,000.

In a 2-1 ruling, the Sixth Circuit disagreed with Judge Haynes’s legal ruling.  The majority explained that her claim has two components: (1) whether Villegas faced a “substantial risk to her health or safety” from being shackled and (2) whether the guards were actually aware of that risk.

The majority recognized that shackling a pregnant detainee while in labor may violate the Constitution but concluded that the right to be free from such treatment is “not unqualified.”  Specifically, there may be situations in which the inmate poses a threat to herself or others or may be likely to escape.  Since Villegas was a “medium security” inmate facing deportation, the court concluded that a jury could find that guards were entitled to restrain her.  Similarly, the court concluded that the guards may not have actually known the risk to Villegas would outweigh the chances of her trying to escape.

The dissenting judge concluded that the trial court’s ruling should stand because none of the disputes of fact are “material” to the case, making a judicial ruling appropriate without the need for a jury to weigh the jail’s liability.