Judge Julie Rikelman, nominated by President Biden to the First Circuit court of appeals, wrote a unanimous opinion that reversed a lower court’s evidentiary rulings that led to a jury verdict against a woman who had sued government officials she contended were responsible for a stillbirth she suffered. The court vacated the jury verdict and ordered a new trial. The February 2024 decision was in Lech v Von Goeler.
What is the background of this case?
“When she was thirty-four weeks pregnant, and during a three-month period of incarceration at a correctional facility in Western Massachusetts, Lidia Lech experienced a stillbirth.” Although the parties strongly disagreed on what happened, Lech contended that correctional and medical officials violated the Eighth Amendment by showing “deliberate indifference” to her “serious medical needs”, resulting in the stillbirth.
In particular, Lech explained that when she was temporarily incarcerated for a probation violation, she was already twenty-two weeks pregnant and was diagnosed as having a high-risk pregnancy due to a previous miscarriage. When she was three weeks away from a scheduled C-section operation, however, she stated that she began reporting “near-daily” problems, such as cramping, decreased fetal movement, and later, vaginal bleeding, and asked to go to the hospital. Nevertheless, she maintained, officials “belittled or ignored her symptoms” and did not allow her to go to the hospital. Officials denied her claims. Eventually she was sent to the hospital and “was told that her baby had passed away.”
Lech later filed suit in federal court against corrections and medical officials. The case against most of the defendants went to a jury trial. The officials’ “central” claim was that Lech “never told the facility’s medical staff about most of the pregnancy-related concerns she claimed to have reported.” The jury returned a verdict against Lech’s claims, and she appealed to the First Circuit.
How Did Judge Rikelman and the First Circuit Rule and Why Is It Important?
Judge Rikelman wrote a unanimous opinion that vacated the jury verdict and sent the case back for retrial because of several important and erroneous evidentiary rulings made by the lower court. Lech’s credibility was a crucial issue during the trial, RIkelman explained, and the lower court had erroneously facilitated the defendants’ attack on her credibility while preventing important efforts to bolster it.
Specifically, RIkelman wrote, the lower court had committed an “abuse of discretion” by allowing officials to play to the jury tapes of Lech’s calls with family on which the officials claimed Lech had been untruthful, on matters unrelated to her medical issues. In addition, the court erroneously refused to allow testimony from a friend of Lech who visited her shortly before she was sent to the hospital and would have corroborated her testimony about the problems she was experiencing and her complaints to officials. Given that the case “hinged on competing credibility assessments,” Rikelman went on, the “outcome of the case” could well have been different if the lower court had not made the erroneous rulings.
Judge Rikelman’s decision is obviously important to Lidia Lech’s efforts to get justice for the harm she suffered at the hands of state officials. It also sets an important precedent, particularly In the First Circuit including Maine, Massachusetts, New Hampshire, Puerto Rico,and Rhode Island, concerning how to handle credibility disputes in cases concerning alleged deliberate indifference by government officials. In addition, the ruling illustrates the importance of promptly confirming fair-minded Biden nominees like Judge Rikelman to our federal courts.