Beddingfield V. City Of Pulaski

Defendant City of Pulaski, a municipal corporation located in Giles County, Tennessee, appeals the district court's order denying its motion for judgment notwithstanding the verdict following a jury verdict in favor of the plaintiff, Georgia Beddingfield, surviving spouse of William Beddingfield. William Beddingfield hanged himself with his own belt while being held in the Pulaski City jail on a DUI charge, and plaintiff brought suit under 42 U.S.C. § 1983. The issues on appeal are: (I) whether the City deliberately promulgated a policy to inadequately train jail facility personnel; and (2) in the absence of such a policy, whether gross negligence or reckless disregard amounting to deliberate indifference to the rights of plaintiff's deceased established § 1983 liability against the City. For the reasons set forth below, we reverse.