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• Jennifer had a history of medical conditions and complications before she was ever arrested. Some of her pre-incarceration medical issues include:

  • Episodes of spontaneous blindness

  • Optic neuritis

  • Antiphospholipid Syndrome 

  • Lupus

  • Undifferentiated Mixed Connective Tissue Disease

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• Once incarcerated, her facilities’ inability or refusal to provide her with necessary medical care threatened her life and amounted to criminal negligence. Her prior conditions deteriorated, and the abuse she faced introduced new ones.

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• Physical assault:

  • Raped on multiple occasions by prison officials while in their medical care.

  • Beaten in retaliation for attempting to report the rape.

  • Handcuffed and shackled to her wheelchair.

  • Deprived of food, water, and medications for 24 hours on at least one occasion.

  • During a fire drill, a guard slammed Jennifer, while in her wheelchair, into a wall, dislocating her thumb and giving her whiplash.

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• Explicit medical malpractice:

  • Neglectfully deprived of blood thinners, heart medication, intravenous immunoglobulin (IVIG), plaquenil, eliquis, metoprolol.

  • Numerous ADA violations, including withholding her wheelchair.

  • Overall deliberate indifference to catastrophic physical and mental declines.

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• A partial list of conditions Jennifer suffered while behind bars includes:

  • A pulmonary embolism on the day she was raped the first time.

  • Rape subsequently leading to:

    • Bladder and kidney infection 

    • Vaginal bleeding 

    • Prolonged incontinence

  • Severe weight loss, with Jennifer bottoming out at 83 lbs.

  • Falling injuries around face and mouth from excessively rough transportation.   

  • Multiple strokes.

  • On-and-off rashes, bleeding sores, heart palpitations, and vomiting blood.