$2.95 Million Verdict for Prisoner Who Died After Jail Staff Ignored Weeks of Medical Pleas

David Allan Woods was arrested in October 2010 on minor charges -- shoplifting and an animal-nuisance violation -- and began a 60-day sentence at Hill-Finklea Detention Center in Berkeley County, South Carolina. He had serious underlying health conditions, including hepatitis C, cirrhosis, and bipolar disorder. Within weeks of his arrival, he filed repeated medical requests describing pain and bloody stools. Those requests went unanswered.

On November 5, 2010, guards found Woods gravely ill. Instead of calling for emergency care, they moved him to an observation cell, where he continued to deteriorate over the weekend without receiving medical attention. He was finally transported to a hospital on Monday morning, November 8. Three days later, he was dead, at 50 years old, from gastrointestinal bleeding, esophageal varices, a duodenal ulcer, and cardiac arrest.

His mother, Nancy Morris, filed a federal civil-rights lawsuit in 2012 under 42 U.S.C. Section 1983, alleging that individual detention officers had acted with deliberate indifference to a serious medical need in violation of the Eighth Amendment. The case was assigned to U.S. District Judge Richard Gergel. Harold C. Staley Jr. and Garrett B. Johnson of Elrod Pope Law Firm served as counsel for the plaintiff, working with co-counsel on the case.

After a trial in October 2014, the jury returned a verdict of $2.95 million. The award included $500,000 in compensatory damages and punitive damages totaling $2.45 million against five individual officers, with two of the defendants -- Richard Burkholder and Priscilla Garrett -- each assessed $1 million in punitive damages and the remaining three assessed $150,000 each. The district court later applied a setoff for settlement proceeds the family had recovered from previously dismissed medical defendants, reducing the compensatory portion to approximately $171,875. The punitive damages were not reduced.

The defendant officers appealed, challenging both liability and the punitive-damages awards as constitutionally excessive. On November 16, 2016, the United States Court of Appeals for the Fourth Circuit affirmed the judgment in full, finding no abuse of discretion in the setoff calculation and rejecting the constitutional challenge to the punitive awards. With attorney fees of $354,293 and costs of $31,820 added to the punitive and reduced compensatory awards, the judgment came to roughly $3 million. Counting a separate $625,000 pretrial settlement the family had reached with a medical provider, the total recovery for Woods's death approached $3.5 million.