Brown v. Washington County

Defendant Washington County appeals from a judgment in a negligence action arising from an incident in which an inmate, Charles Brown, escaped from the Washington County Community Corrections Center and killed his brother, Stephen Brown. Defendant 1 assigns error to the trial court’s denial of its motions for directed verdict or judgment notwithstanding the verdict (JNOV) on issues of liability under section 319 of the Restatement (Second) of Torts (1965) and principles of general foreseeability. Plaintiff, Stephen Brown’s personal representative and widow, cross-appeals, asserting that the…