This case arises out of Plaintiff Gregory Palm’s claim that he received deficient medical care while incarcerated in the Jones County Jail and Baldwin County Detention Center.
Sheriff Butch Reese, Captain Shane Moody, Lieutenant Brent Skinner, and Lieutenant Dalton Hart (hereinafter “Defendants”) disclosed Kathryn Wild and Paul Cappitelli as expert witnesses. Plaintiff Gregory Palm filed a motion to exclude the testimony of these witnesses.
Nursing Expert Witness
Kathryn Jean Wild has extensive experience working alongside, supervising, and training correctional officers regarding their responsibilities and duties as they relate to the provision of healthcare in a correctional facility.
Wild is a registered nurse with a bachelor’s degree in health services management and a master’s in public administration. She has worked in the field of correctional healthcare for forty years and has been certified as a correctional healthcare professional since 1991.
Law Enforcement Expert Witness
Paul A. Cappitelli is a career law enforcement officer with extensive experience working in administration, patrol, custody, homicide investigation, public affairs, and gang enforcement.
Discussion by the Court
Expert Testimony of Kathryn Wild
Palm asserted that Wild is not qualified to opine about the conduct of jail correctional officers because she is a nurse and not a correctional officer herself.
Wild is a registered nurse who has worked in the correctional healthcare setting for nearly forty years. She worked as a nurse in five correctional facilities, then went on to serve as the health services administrator for San Bernardino County, California, and the deputy agency director for correctional health services for Orange County, California. In her supervisory roles for San Bernardino County and Orange County, she was responsible for the oversight and training of non-medical staff such as corrections officers regarding the provision of healthcare services and she developed and implemented the healthcare policies that governed correctional facility employees.
She now operates a consulting business in which she assists in training correctional facility staff, including correctional officers, on their responsibilities relating to the provision of healthcare for inmates and detainees.
The Court found that Wild is qualified to opine on the conduct of correctional officers in this action. While she may not be a correctional officer, Wild is familiar with (and has even participated in the creation of) standards governing the involvement of correctional officers in the provision of healthcare to detained individuals. She has first-hand experience training such officers on how they should provide healthcare to those in their custody. Wild’s knowledge and experience concerning the standards for correctional officers’ responsibilities relating to healthcare rendered her qualified to offer expert testimony in this action.
Having found that Wild was qualified to provide expert testimony on the subjects explained hereinabove, the Court found unpersuasive Palm’s argument that Wild’s testimony would be unreliable and unhelpful to the trier of fact.
Expert Testimony of Paul Cappitelli
Palm argued that Paul Cappitelli’s testimony should be excluded because it will not help the trier of fact understand the evidence or determine a fact at issue.
Cappitelli is a career law enforcement officer who opines that the jail staff in this action “were attentive and conscientious in their interactions with Palm” and “arranged for [Palm] to receive medical treatment” when they first noticed his need for medical attention, such that he was never denied medical care.
He also opined that Palm was properly monitored during his incarceration in conditions that were adequate, and that there is no evidence that any policy or practice could have altered Palm’s health outcome.
Cappitelli asserted that the jail staff were adequately trained and not responsible for medical care decisions. He based these opinions on “the standard of care prevalent in the corrections and custodial profession and facilities, and the practices of corrections personnel in this matter.”
Cappitelli is familiar with the standard of care unique to the corrections environment because he has extensive experience “personally supervis[ing] numerous officers and professional staff support employees in a custody environment.”
In summary, the Court held that Cappitelli’s expert testimony regarding the standard of care in an involuntary detention setting, and whether the Defendants met that standard of care under the circumstances in this action, will assist the trier of fact.
Held
The Court denied Palm’s motion to exclude the testimony of Defendants’ expert witnesses, Kathryn Wild and Paul Cappitelli.
Key Takeaway:
Monitoring detainees or prisoners in a correctional environment is distinct from monitoring someone in the home or office in a way that average jurors may be familiar with. That unique setting carries with it a unique standard of care which the average layperson will likely need expert assistance to understand.
Cappitelli’s testimony about the standard of care applicable to custodial officers in an involuntary detention setting goes beyond “what lawyers for the parties can argue in closing arguments.” As long as Cappitelli connects his conclusions and opinions to the unique standard of care and special circumstances in the detention setting, they may be helpful to the jury.
Case Details:
| Case Caption: | Palm V. Corrcare Inc Et Al |
| Docket Number: | 3:24cv47 |
| Court Name: | United States District Court, Georgia Middle |
| Order Date | August 11, 2025 |
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