City of Louisville v. Humphrey – Case Brief
City of Louisville v. Humphrey, 461 S.W.2d 352 (Ky. 1970).
Facts: Ruel Humphrey was found wandering the city streets intoxicated at 2:15 AM. He was arrested and taken to city jail at 2:35 AM. At 4:15 AM he was taken to the drunk tank and was left lying on the floor with his feet towards the entrance. At 7:15 AM he could not be awakened and at noon he was taken unconscious to a local hospital. He was diagnosed with a subdural hematoma from injuries apparently received around the left eye and forehead. Ruel underwent brain surgery and died three weeks later without ever having regained consciousness. Mary Humphrey (P) sued the City of Louisville (D) and was awarded $59,534.34. D appealed.
Issue: Does res ipsa loquitur apply in a case in which a person dies in the custody of a prison, where there is no evidence of who or precisely what caused the injuries?
Holding and Rule: No. Res ipsa loquitur does not apply in a case in which a person dies in the custody of a prison, where there is no evidence of who or precisely what caused the injuries.
The court held that there was no direct evidence that Ruel was injured by a prisoner, prison guard, or a police officer and that the court was left to speculate who was responsible. If a prisoner had been responsible for the injury, the city would not be liable unless it had knowledge of the violent propensities of that prisoner. A keeper of a prison is not the absolute insurer of the safety and well being of a prisoner.