Hamilton v. Ohio Dept. of Rehab. & Corr.

Citations

• 2023 Ohio 3143

Syllabus

Negligence Inmate Duty of Care Prison Officials Constructive Notice Notice Impending Attack. Plaintiff alleged Defendant was negligent when Defendant placed Plaintiff in general population of prison despite plaintiff's oral request to be placed in protective custody. Plaintiff was subsequently injured when another inmate threw scalding water at him and assaulted him. The Court concluded that Plaintiff failed to prove that Defendant had actual knowledge of an impending attack. The Court further found that Plaintiff's oral request for protective custody did not put Defendant on constructive notice of an impending inmate attack, and that Plaintiff had failed to prove that the criminal convictions for which he was incarcerated merited automatic placement in protective custody. Thus, Defendant did not breach a duty of care to Plaintiff. Judgment rendered for Defendant.