Lake v. CoreCivic

CourtDistrict Court, D. Montana
DecidedAugust 6, 2025
Docket4:21-cv-00116
StatusUnknown

This text of Lake v. CoreCivic (Lake v. CoreCivic) is published on Counsel Stack Legal Research, covering District Court, D. Montana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lake v. CoreCivic, (D. Mont. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA GREAT FALLS DIVISION NATHANIEL LAKE,

Cause No. CV-21-116-GF-BMM Plaintiff,

vs. ORDER

CORECIVIC, INC., d/b/a CROSSROADS CORRECTIONAL CENTER, WARDEN PAT MCTIGHE, and DOES 1-10,

Defendants.

INTRODUCTION

The Court addresses two outstanding motions. Defendants CoreCivic, Inc., Warden Pat McTighe, and Does 1-10 (“CoreCivic”) filed a motion for production of Plaintiff's opening and closing statement materials. (Doc. 120.) Plaintiff Nathaniel Lake (“Lake”) opposes the motion. (Doc. 126.) CoreCivic filed a motion for judgment as a matter of law and, in the alternative, motion for a new trial. (Doc. 128.) Lake opposes the motion. (Doc. 136.) The Court held a hearing on the motions on July 17, 2025. (Doc. 145.) BACKGROUND 1 The Court will not repeat the details of this case at length. See Lake v. Corecivic, Inc., 2023 WL 6379349 (D. Mont. Sept. 29, 2023). This case was tried

before a jury over four days from April 21, 2025, to April 24, 2025. (Doc. 82; Doc. 89; Doc. 92; Doc. 93.) The jury returned a $27,750,000 verdict for Lake. (Doc. 101.) CoreCivic then filed various post-trial motions. The Court will address first

CoreCivic’s motion for production of Lake’s opening and closing statement materials. The Court will address second CoreCivic’s motion for judgment as a matter of law and, in the alternative, motion for a new trial. DISCUSSION

I. CoreCivic’s Motion for Production of Lake’s Opening and Closing Statement Materials

CoreCivic asks the Court to order the production of PowerPoint slides used during opening and closing statements. (Doc. 135 at 2.) Lake opposes the motion. (Doc. 126.) The Court will order Lake to produce the PowerPoint slides. The First Amendment of the United States Constitution creates a presumptive right of access to judicial records in civil cases. See Courthouse News Serv. v. Planet, 947 F.3d 581, 591 (9th Cir. 2020). Documents displayed in open court are not protected by work-product immunity. See United States v. Sanmina Corp., 968 F.3d

1107, 1119 (9th Cir. 2020). Courts may order demonstrative slides to be released even where the party seeking the slides did not move the court for their production 2 at trial. See, e.g., United States v. Yandell, 2024 WL 2209738 (E.D. Cal. May 16, 2024); Wrice v. Byrne, 488 F. Supp. 3d 646, 652, 679 (N.D. Ill. 2020). Courts have

additionally required parties to file demonstrative exhibits used at trial to create a complete record for appeal. See Yandell, 2024 WL 2209738 at *1. Federal Rule of Appellate Procedure 10 provides that a district court retains

the authority to address certain issues related to the record on appeal. See Fed. R. App. P. 10(e)(1)(-2) (stating that, “[i]f any difference arises about whether the record truly discloses what occurred in the district court, the difference must be submitted to and settled by that court and the record conformed accordingly.”); see also In re

HIV Antitrust Litig., 2024 WL 923551 (N.D. Cal. Mar. 1, 2024). The purpose behind Federal Rule of Appellate Procedure 10: is to ensure that the record on appeal accurately reflects the proceedings in the trial court (thereby allowing us to review the decision that the trial court made in light of the information that was actually before it), not to enable the losing party to add new material to the record in order to collaterally attack the trial court's judgment.

United States v. Elizalde-Adame, 262 F.3d 637, 641 (7th Cir. 2001)

The Court does not find that Lake would be prejudiced by producing the PowerPoints. “The Ninth Circuit, of course, will be aware that the demonstrative is simply an aid, and not evidence . . . the appellate court will not be misled into looking at the demonstratives as an independent source of information, but simply as an aid to understand the record testimony.” In re HIV Antitrust Litig., 2024 WL 923551 at 3 *3. The Court will order Lake to produce the materials used during opening and closing statements.

II. CoreCivic’s Motion for Judgment as a Matter of Law and, in the alternative, Motion for a New Trial

CoreCivic renews its motion for judgment as a matter of law arguing that there was no evidence that any CoreCivic employee acted with deliberate indifference. (Doc. 129 at 7–8.) CoreCivic also argues that Lake’s expert Jennifer Crowley was unqualified to testify about Lake’s shortened lifespan. (Id. at 8–9.) CoreCivic moves, in the alternative, for a new trial on liability based on four theories, and a new trial on damages. (Id. at 9–31.) The Court will address each issue in turn. A. CoreCivic’s Motion for Judgment as a Matter of Law

Federal Rule of Civil Procedure 50(a)(1) directs a court to render judgment as a matter of law when “a party has been fully heard on an issue during a jury trial and the court finds that a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on that issue.” Judgment as a matter of law proves improper

if a jury verdict is supported by “substantial evidence.” Wallace v. City of San Diego, 479 F.3d 616, 624 (9th Cir. 2007). In assessing a judgment as a matter of a law a court must review all the evidence in the record and draw “all reasonable inferences

in favor of the nonmoving party, and it may not make credibility determinations or

4 weigh the evidence.” Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150 (2000).

1. Deliberate Indifference

CoreCivic argues that there was no evidence of deliberate indifference by any CoreCivic employee, which is necessary for an Eighth Amendment failure-to- protect claim. (Doc. 129 at 7.) CoreCivic contends that Lake did not present evidence that any employee knew of a substantial risk of harm from Reid Danell. (Id.) The Court finds that substantial evidence supported the jury’s verdict. A failure to protect claim in the prison context is established by presenting

evidence that prison employee(s) acted with “deliberate indifference.” Farmer v. Brennan, 511 U.S. 825, 843 (1994). Deliberate indifference is established by showing that prison employee(s) knew of and disregarded a “substantial risk to

inmate safety.” Id. Lake presented substantial evidence that supported the jury’s finding of deliberate indifference. Lake presented evidence that CoreCivic was required, but failed, to follow an objective inmate classification system established by the State of

Montana. (See Doc. 130 at 77–80, 82–133; see also Doc. 105-13, Doc. 105-16; Doc. 106-2.) CoreCivic’s failure to follow the inmate classification system resulted in a prison with higher classifications—those considered more dangerous—to be placed

with lower-security prisoners, like Lake. (See id.; see also Doc. 106-7; Doc. 131 at 5 62–75.) CoreCivic also was contractually required to segregate and provide mental health services to prisoners with mental health disorders. (See Doc.

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Lake v. CoreCivic, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lake-v-corecivic-mtd-2025.