Ling V. Campbell County, Tennessee Et Al

Case Background

On June 01, 2020, a civil rights action was initiated against Campbell County, Tennessee for failure to train staff to prevent abuse and provide needed medical assistance to jail detainees. The action was filed before the United States District Court, Tennessee Eastern (Knoxville) seeking damages for the life-altering injuries inflicted on Nathan Ling while in detention.

The case was assigned to District Judge Charles E Atchley, Jr and referred to Magistrate Judge Jill E McCook. [Case number: 3:20cv233]

Cause

On June 1, 2019, a 911 call was made about a suspicious vehicle. Deputy Crabtree and other Campbell County Sheriff’s Department officers responded, locating the vehicle with Nathan Ling, Kaitlyn McDaniel, and Jaevon Dayshawn Jones inside.

During the investigation, officers discovered the vehicle was stolen in Michigan. McDaniel admitted she took it without permission. Additionally, Ling had active felony warrants in Michigan. A deputy tried to arrest him, but Ling attempted to flee.

After being apprehended, EMS evaluated Ling but he became combative. After medical clearance, Deputy Crabtree transported Ling to the Campbell County Correction Center around 12:30 a.m. on June 2, 2019. Handcuffed behind his back, Ling was roughly removed from the cruiser by Crabtree, who threw him towards the floor. Crabtree then shoved Ling against the wall and door.

Inside the intake area, Crabtree, Correctional Officer Joshua Miller, and Corporal Sean Brown positioned Ling facing the intake counter. Crabtree forcefully slammed Ling’s head against the counter and window frame.

Ling was then handed over to Miller and Brown. As he attempted to rise, they, along with Crabtree, violently slammed him to the floor. Despite Ling not resisting, Crabtree struck him in the face, causing a nosebleed. Crabtree used additional force and pressed his boot into Ling’s spine. Corporal Brown sprayed Ling with a chemical agent, and they placed a spit mask over his head.

Ling was left in the decontamination area without medical attention for over six hours. Medical care only started after shift change, around 7:20 a.m. Later, the investigation revealed that the facility’s contract with Quality Correctional Health Care did not require a medical provider overnight. Corporal Brown allegedly photographed Ling in his injured state and shared these photos with the Sheriff’s Department.

Injury

Following his serious and life-threatening injuries, Mr. Ling was first taken to the emergency department at LaFollette Medical Center. Due to the severity of his injuries, he was then airlifted to the University of Tennessee Medical Center. There, doctors diagnosed him with several severe conditions: a pneumothorax (collapsed lung), an orbital fracture (bones around the eye socket), a maxillary fracture (the bridge between the cranial base and dental plate), a nasal bone fracture, a closed fracture of the greater tuberosity of the left humerus (a prominent bone area from shoulder to elbow), and a traumatic brain injury.

Ling continues to suffer from these injuries, which have caused him permanent physical and mental distress. A guardian ad litem was appointed to manage his affairs. Due to his brain injury, he was unable to attend the entire trial.

Damages

Plaintiff Nathan Ling requested compensatory damages totaling $25,000,000.00 from all Defendants under 42 U.S.C. Sec. 1983. Additionally, he asked for compensatory damages in the maximum amount allowed under the Tennessee Governmental Tort Liability Act. Furthermore, he sought punitive damages of $25,000,000.00 from all Defendants, excluding Campbell County, Tennessee, under 42 U.S.C. Sec. 1983.

He requested that the Court award attorney’s fees as provided by 42 U.S.C. Sec. 1988, along with costs associated with the action, including discretionary costs. Lastly, he asked for any other or further relief to which he might be entitled.

Key Arguments and Proceedings

Legal Representation

  • Defendant(s): Campbell County, Tennessee
    • Counsel for Defendant(s): Arthur F Knight , III | Jonathan Swann Taylor

Claims

1. Excessive Force: Deputy Crabtree, Deputy Williams, and Corporal Brown used excessive force against Mr. Ling. They slammed him into a floor, wall, countertop, and window frame. They threw him to the ground, punched him, applied pressure across his body, sprayed him with a chemical agent, and placed a spit mask over his head while he lay handcuffed and bloodied. The officers also took degrading photographs of him in this state. The Defendants’ actions were deemed objectively unreasonable, representing an arbitrary exercise of power and excessive force that violated the Fourteenth Amendment’s Due Process Clause. They were aware or should have been aware, of Mr. Ling’s severe medical condition resulting from their actions and failed to provide immediate medical care.

2. Deliberate Indifference to Medical Needs: The Defendants, including the John Doe Defendants, failed to provide emergency medical care for approximately seven hours despite knowing Mr. Ling’s condition from incident footage and his complaints. This failure led to a violation of his due process rights under the Fourteenth Amendment. The officers’ deliberate indifference resulted in Ling suffering severe injuries.

3. Municipal Liability: Campbell County, Tennessee, faced liability under the Fourteenth Amendment for having policies or customs that caused constitutional violations. The County’s failure to train its officers properly in handling restrained detainees and in intervening against excessive force contributed to the officers’ negligent assault on Ling. Proper training would have prevented his severe injuries. Additionally, Campbell County was liable for ratifying the illegal actions of its officers, as its customs and policies facilitated the violation of Ling’s rights to protection from excessive force and timely medical care.

By the time of the trial, Ling had withdrawn all his claims against the individual defendants. The sole remaining focus was Campbell County.

Defense

Campbell County denied any fault and claimed its staff had received adequate training, asserting that the training was not so deficient as to amount to deliberate indifference. However, two key pieces of evidence undermined this defense: first, jail staff testified that they had received virtually no training, and second, the jail video captured the brutal attack. Additionally, they downplayed the severity of Ling’s ongoing injuries.

Expert Testimony

Experts for the Plaintiff included Roy Taylor, Ph.D., Robert Bohm, Ph.D., Michael Galloway, MS, CRC, ABDA, and Greg P. Winston, MS. His damages were quantified, in part, by a life care planner, Courtney Whatley, who described Ling’s future medical needs and in-home care.

Jury Verdict

On February 2, 2024, the jury found Campbell County liable under 42 U.S.C. Sec. 1983 for failing to train staff to prevent abuse. The jury awarded Ling $6,000,000 in compensatory damages. However, they did not find Campbell County liable for failing to provide medical assistance.

On February 5, 2024, Judge Atchley entered a judgment in favor of Nathan Ling, awarding him $6,000,000.00 with post-judgment interest as specified by 28 U.S.C. Sec. 1961.

Court Documents:

Available upon request