September 19, 2016

            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...

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