## Facts

- Lesa Hunt was an inmate in the custody of the Ohio Department of Rehabilitation and Correction (ODRC) at the Northeast Pre-Release Center.
- On January 23, 1995, Hunt was assigned to an outside yard crew and was told to clear sidewalks using a Gravely snowblower.
- Corrections Officer Carl Jenkins supervised the yard crew and assigned Hunt (and another inmate) to operate the snowblower.
- Neither Hunt nor Jenkins had previously operated a snowblower.
- Jenkins had received training about a week earlier from Woody Meyers, the head of the maintenance department.
- Meyers instructed Jenkins that, if the chute became clogged, the operator should (1) disengage the Power Take Off (PTO), (2) shut the engine down completely using the key, and (3) clear the clog with water or a device—not by using a hand.
- Before work began, Jenkins gave Hunt roughly ten minutes of instruction on operating the snowblower.
- While Hunt was using the snowblower, the chute clogged with snow.
- Hunt put the machine in neutral and turned the PTO switch to “off,” believing that this shut down the dangerous moving parts; however, parts of the blower could still spin.
- After looking into the chute, Hunt inserted her gloved hand to remove packed snow; the machine caught the glove and pulled her hand into the chute.
- Hunt pulled her hand free, but parts of three fingers on her right hand were partially severed.
- Hunt sued ODRC in the Ohio Court of Claims, alleging negligent training and negligent supervision; the case proceeded to a bench trial on liability (with damages addressed later).

## Issues

1. Whether ODRC breached its duty of reasonable care to an inmate by failing to provide adequate training and supervision for operating a snowblower, including safe procedures for clearing clogs.
2. Whether Hunt’s conduct constituted comparative negligence and, if so, what percentage of fault should be allocated to Hunt and to ODRC.

## Decision

- The Court of Claims found ODRC negligent in the training and supervision provided for Hunt’s operation of the snowblower.
- The court found that the training was insufficient given the danger of the equipment, Jenkins’s lack of experience, and the limited instruction given to Hunt.
- The court also found Hunt comparatively negligent for putting her hand into the chute without fully shutting down the machine by turning off the engine with the key.
- Fault was apportioned 60% to ODRC and 40% to Hunt, requiring a proportional reduction of any damages award.

## Legal Principles

- The state owes inmates a duty of reasonable care, reflecting the custodial relationship and the limits incarceration places on an inmate’s ability to avoid risk.
- When assigning inmates to operate potentially dangerous machinery, reasonable care includes adequate instruction and warnings about known hazards and safe operating procedures.
- Inadequate training and supervision may constitute a breach when an inexperienced supervisor provides minimal instruction and fails to ensure that key safety steps are communicated and followed.
- Under Ohio’s modified comparative negligence approach, a plaintiff whose negligence is less than the defendant’s may recover, but damages are reduced in proportion to the plaintiff’s percentage of fault.

## Conclusion

The Ohio Court of Claims held that ODRC breached its duty of reasonable care by inadequately training and supervising inmate Lesa Hunt in operating a snowblower and in safely clearing clogs, but it reduced Hunt’s recovery under comparative negligence because Hunt was 40% at fault for placing her hand into the chute without fully shutting down the engine.


Hunt v. Ohio Dept. of Rehabilitation & Correction, 696 N.E.2d 674 (1997)