Deceased inmate’s estate case against DOC reinstated on appeal

The estate of an inmate who died in the Indiana Department of Corrections from complications arising from lupus and a blood clotting disorder had its case reinstated Monday against the DOC and its medical services contractor.

At the time of Rachel Wood’s death in 2012, medical service provider Corizon Health was under contract with the DOC to provide medical services at the various facilities where Wood was housed. Its contract required that Corizon provide medically appropriate care to inmates, maintain records for contract monitoring by the DOC, and comply with the DOC’s written health care services directives. Those directives, in turn, required Corizon to establish and maintain formal written plans for the treatment of inmates with serious health problems.

While Wood was serving time at the Rockville Correctional Facility, a Corizon doctor allowed the hydroxychloroquine prescription for Wood’s lupus to expire after she was “noncompliant” and had not taken the medication in more than a month. The doctor afterward did not counsel Wood about the importance of being compliant with that prescription and did not consult with a specialist or otherwise establish a long-term treatment plan for her lupus.

Electronic medical records created by the Corizon doctor and a nurse practitioner also failed to show any consistent provider response to Wood’s abnormal blood clotting tests during her time at the Rockville facility, leaving it unclear of what dosages of warfarin, if any, Wood actually received. The same thing happened while Wood was housed at the Madison Correctional Facility.

Corizon medical employees at the Madison facility failed to restart Wood’s lupus prescription when she showed increased inflammation, instead prescribing her steroids over the next several months. During the months that followed, Wood’s health began to deteriorate, leaving her weak and unable to eat or stand on her own, requiring her cellmates to help her use the bathroom, bathe and even write. Wood’s skin was covered in rashes and she experienced bleeding from her ears, nose and gums, but other inmates noted that “no one wanted to listen” when Wood attempted to tell medical staff of her condition.

Wood was eventually transferred to the Indianapolis Indiana Women’s Prison because it had an infirmary, where she spent four days before being transported by ambulance to Terre Haute Regional Hospital for hypoxia. Three weeks later, Wood was discharged and transported by ambulance back to the prison, only to be transferred by Corizon to Kindred Hospital. En route back to Indianapolis, Wood began coughing up blood in the ambulance and died.

Wood’s estate later sued the DOC, Corizon and Corizon’s medical employees, asserting that the Corizon medical employees were “deliberately indifferent” to Wood’s “serious medical needs, which constituted cruel and unusual punishment in violation of the Eighth Amendment to the United States Constitution.” It also asserted that the DOC failed “to ensure that . . . Corizon carried out its contractual duty to provide reasonable medical care” to Wood.

The Marion Superior Court ultimately entered judgment for the defendants, but a panel of the  Indiana Court of Appeals reversed and remanded in a 43-page opinion in Sue Williams, Linda Wood, and Claude Wood, as the Co-Personal Representatives of the Estate of Rachel A. Wood, Deceased v. Indiana Department of Correction, Corizon, Inc., et al., 19A-CT-1832.

Although it found that two Corizon nurses at the Indiana Women’s Prison did not breach the standard of care or act in a plainly inappropriate manner when dealing with Woods, the appellate court concluded that genuine issues of material fact precluded the entry of summary judgment for Corizon medical providers Dr. Richard Hinchman, Dr. Vance Raham, Dr. Daniel Rains, and nurse practitioners Dawn Antle and Georgeanne Pinkston.

“The record does not suggest a single or isolated instance of medical mistreatment, nor does it suggest that Wood’s medical providers reasonably responded to her needs but simply failed to avert harm. The record instead shows systemic and gross deficiencies in her medical care throughout her incarceration, which deficiencies the Estate’s expert directly connected to her cause of death. Genuine issues of material fact support at least an inference that Wood’s medical providers ‘disregard[ed] an excessive risk to [Wood’s] health or safety,’” Judge Edward Najam wrote for the appellate panel.

Additionally, the appellate panel found the trial court erred in granting summary judgment to Corizon and the DOC, concluding that the evidence designated by the parties with respect to the estate’s claims against the Corizon medical employees was relevant and available against Corizon under the doctrine of respondeat superior.

Likewise, the appellate court found genuine issues of material fact precluded the entry of summary judgment for the DOC on the questions of breach and proximate causation.