Georgia Courts want Reports and Records, not Deliberate Indifference

The Georgia Court of Appeals recently reaffirmed the high burden of proof required in a § 1983 claim. McKuhen v. TransformHealthRX, Inc., 2016 WL 3877289 (Ga. Ct. App. 2016). On January 30, 2012, Carol McKuhen, a prisoner in Effingham County jail, was found dead in her isolation cell. An autopsy determined that she died of chronic ethanolism with hypertensive heart disease. McKuhen's surviving spouse and the co-administrators of her estate, filed a civil action under 42 U.S.C. § 1983 against the jail personnel (collectively “Jail Defendants”), TransformHealthRX, Inc. (“THRX”), and the medical staff employed by THRX (collectively “Medical Defendants”). The McKuhen’s alleged that the Medic

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