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Sanford v. Commonwealth of Virginia

United States District Court for the Eastern District of Virginia
687 F. Supp. 2d 591 (2009)


Facts

John Sanford was a mentally and physically disabled individual who was admitted to the Medical College of Virginia Main Hospital (MCV) for surgery. Following the surgery, Sanford became delirious as a result of medications that had been administered to him. MCV nurses summoned police officers and a security guard to restrain Sanford. The security guard and one of the police officers handcuffed Sanford and held him prone and facedown on the floor. During this period, a nurse injected Sanford with a sedative. Additional officers responded to the scene, and Sanford was restrained in the same position for 30 minutes. When Sanford was finally turned over, he was dead. Sanford’s estate (plaintiffs) filed suit. One attorney represented multiple MCV employees (defendants), including nurses, nurse supervisors, security staff, and doctors. Another attorney represented multiple police officers (defendants), including the first responding officer, supervising officers, and officers who arrived at the scene later. During initial testimony, conflicting information and various theories of culpability emerged among both the group of MCV employee defendants and among the group of police officer defendants. The plaintiffs filed a motion to disqualify both the MCV employee defendants’ attorney and the police officer defendants’ attorney for conflicts of interest.

Rule of Law

Issue

Holding and Reasoning (Payne, J.)

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