Prevention of Future Deaths reports · 2024

Paul Day

Regulation 28 report to prevent future deaths, reference 2024-0274, written 10 May 2024. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report10 May 2024
Reference2024-0274
DeceasedPaul Day
CoronerPeter Nieto
Coroner areaDerby and Derbyshire
CategoryAlcohol, drug and medication related deaths · State Custody related deaths
Sourcejudiciary.uk record · original PDF
Responses published1

The report

Text extracted from the PDF text layer. Reproduced verbatim, including the scan's own layout.

Regulation 28: REPORT TO PREVENT FUTURE DEATHS 

NOTE:  This form is to be used after an inquest. 

REGULATION 28 REPORT TO PREVENT DEATHS 

THIS REPORT IS BEING SENT TO:  

The Rt Hon Alex Chalk KC MP, Secretary of State for Justice 
102 Petty France 
London 
SW1H 9AJ 
United Kingdom 

1  CORONER 

I am Peter Nieto, senior coroner for the coroner area of Derby and Derbyshire. 

2  CORONER’S LEGAL POWERS 

I make this report under paragraph 7, Schedule 5, of the Coroners and Justice Act 2009 and 
regulations 28 and 29 of the Coroners (Investigations) Regulations 2013. 

3 

INVESTIGATION and INQUEST 

On 23 March 2017 I commenced an investigation into the death of Paul Edward DAY aged 55.  
The investigation concluded at the end of the inquest on 9 May 2024.  Mr Day was a prisoner 
at HMP Sudbury at the time of his death and as his death appeared unnatural his inquest was 
a jury inquest. The inquest also examined whether there were any acts or omissions by prison 
staff that contributed to the death. The inquest engaged Art. 2 ECHR. The jury reached a short-
form conclusion of drug related death but made a finding of omission which, on the evidence, 
could not be established as contributory to death.  

4  CIRCUMSTANCES OF THE DEATH 

I  will  only  detail  those  circumstances  which  are  relevant  and  assist  understanding  of  my 
concerns. 

On the night of 22 March 2017 Mr Day was discovered collapsed in a cubicle in the toilet block 
of the prison wing where he was placed. There was cold water gushing over him from a broken 
pipe  to  the  toilet  cistern  which  had  likely  broken  during  his  collapse.  The  attending  prison 
officers could not detect a pulse or breathing. The senior officer also believed him to be in a 
state of rigor mortis and considered he was dead. Factors cited by the officer for the belief that 
rigor mortis was present were: cold body temperature; pallor; the neck and wrist appearing 
firm when a pulse was felt for. However, it is not apparent that those were good reasons to 
consider  rigor  mortis  was  present  as  Mr  Day  was  not  moved  and  had  been  exposed  to  cold 
running  water,  and  it  was  very  unlikely  that  there  had  been  sufficient  time  for  this  to  have 
occurred.  

No  CPR  was  attempted,  and  Mr  Day  was  left  in-situ,  without  being  moved  at  all  until  an 
attending  paramedic,  who  had  arrived  approximately  15  minutes  after  the  officers  first 
attended Mr Day, pulled him into the corridor and began CPR and subsequent advanced life -
support, after which there was a return of spontaneous circulation. Mr Day was taken to hospital 
but went into a further cardiac arrest and died in the early hours of the morning of 23 March. 

CONTROLLED 

Regulation 28 – After Inquest 
Document Template Updated 30/07/2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 On the post-mortem and circumstantial evidence Mr Day’s cause of death was found to be 1a 
Toxic  Effects  of  Synthetic  Cannabinoids. 

The jury found and recorded that: - 

Prison staff who attended Mr Day on the night of 22 March 2017 when he was found collapsed 
in the toilet cubicle should have performed CPR on him because: - 

 - CPR should be attempted in all situations excluding certain extreme circumstances. 

 - Staff were unqualified to recognise the signs of rigour mortis which was one of the exclusions. 

 - Preservation of life should always be the primary goal. 

Although the jury finds that the prison staff should have performed CPR, the jury does not find 
on the evidence that this omission contributed to Mr Day's death. 

The first bullet-pointed reason given by the jury relates to the HMP Sudbury Staff Information 
Notice at the time (the current Notice is the same), Guidance to support the decision-making 
process of whether to perform CPR in prisons. The guidance stated that:  Resuscitation MUST 
be  started  on  all  people  who  are  found  not  breathing  and/or  pulseless  unless  one  of  the 
following  reasons/circumstances  applies:  Hypostasis/Lividity;  Rigor  Mortis;  Decapitation; 
Massive  Cranial  and  Cerebral  Destruction;  Incineration;  Traumatic  Hemicorporectomy; 
Decomposition/Putrefaction. 

Three of the four prison staff who attended Mr Day were first aid trained, this included training 
in performing CPR. The training did not and still does not include assessing for and identifying 
rigor mortis, or verification of death. 

HMP Sudbury is an open prison and does not have seven day a week 24-hour healthcare staff 
presence.  

On the evidence it was quite possible that Mr Day had reached a point, by the time the prison 
officers  attended  him,  where  CPR  would  not  have  prevented  his  death,  notwithstanding  the 
clear opportunity for this to have been attempted.   

5  CORONER’S CONCERNS 

During the investigation my inquiries revealed matters giving rise to concern. In my opinion 
there is a risk that future deaths could occur unless action is taken.  In the circumstances it is 
my statutory duty to report to you. 

The MATTERS OF CONCERN are as follows: - 

1.  I  understand  that  the  prison  guidance  re  CPR  which  I  have  referenced,  is  in  effect 
guidance  provided  nationally  to  all  prisons.  The  inclusion  of  rigor  mortis  in  the 
exclusions for CPR is something of an outlier as compared to the other reasons which 
would  clearly  and  obviously  evidence  that  death  had  occurred,  even  to  someone 
without first aid training. In those prisons without 24-hour healthcare staffing prison 
officer staff are operating under guidance that they are not trained to be able to follow 
(re rigor mortis). In prisons with 24-hour healthcare staffing it is likely that healthcare 
staff would attend a resuscitation incident.  

2.  Given the current guidance, in those prisons without 24-hour healthcare staffing, and 
where prison officer staff attend a prisoner in a state of collapse who is not breathing 
and is pulseless, there is the clear potential to mistakenly assess the person to be in a 
state of rigor mortis, and thus miss the opportunity to undertake CPR and potentially 
prevent  death,  because  quite  clearly  they  have  not  been  trained  to  assess  for  and 
recognise rigor mortis. This was very clearly illustrated in Mr Day’s inquest.  

CONTROLLED 

Regulation 28 – After Inquest 
Document Template Updated 30/07/2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 3.  The current CPR guidance does not appear to be appropriate for those prisons without 
24-hour healthcare staffing, and in my view presents the real risk that future deaths 
could occur unless action is taken.  

6  ACTION SHOULD BE TAKEN 

In my opinion action should be taken to prevent future deaths and I believe you (and/or your 
organisation) have the power to take such action. 

7  YOUR RESPONSE 

You are under a duty to respond to this report within 56 days of the date of this report,  
namely by July 05, 2024.  I, the coroner, may extend the period. 

Your response must contain details of action taken or proposed to be taken, setting out the 
timetable for action.  Otherwise you must explain why no action is proposed. 

8  COPIES and PUBLICATION 

I have sent a copy of my report to the Chief Coroner and to the following Interested Persons      

• 

• 

The Governor HMP Sudbury 

, partner 

I have also sent it to         

• 

Practice Plus Group, healthcare provider at HMP Sudbury 

who may find it useful or of interest. 

I am also under a duty to send a copy of your response to the Chief Coroner and all interested 
persons who in my opinion should receive it. 

I may also send a copy of your response to any person who I believe may find it useful or of 
interest. 

The Chief Coroner may publish either or both in a complete or redacted or summary form.  He 
may send a copy of this report to any person who he believes may find it useful or of interest.   

You  may  make  representations  to  me,  the  coroner,  at  the  time  of  your  response  about  the 
release or the publication of your response by the Chief Coroner. 

9 

 Dated: 10 May 2024 

Peter Nieto 

Senior coroner  

Derby and Derbyshire  

CONTROLLED 

Regulation 28 – After Inquest 
Document Template Updated 30/07/2021

Responses

1 response published against this report on judiciary.uk. A response is a body's written reply to the coroner's concerns; publication is at the discretion of the Chief Coroner's office, so an absent response does not mean nobody replied.

Response from Hmpps (PDF)
Phil Copple 
Director General Operations 
HM Prison and Probation Service 
8th Floor Ministry of Justice 
102 Petty France 
London  
SW1H 9AJ 

Mr Peter Nieto 
Senior Coroner for Derby and Derbyshire 
St Katherin’s House 
St Mary’s Wharf 
Mansfield Road 
Derby 
DE1 3TQ 

1 August 2024 

Dear Mr Nieto 

Thank you for your Regulation 28 report of 10 May 2024, addressed to the Secretary of 
State for Justice. I am responding on behalf of His Majesty’s Prison and Probation Service 
(HMPPS) as Director General of Operations. 

I know that you will share a copy of this response with Mr Day’s family, and I would first like 
to express my condolences for their loss. Every death in custody is a tragedy and the safety 
of those in our care is my absolute priority. 

You have raised concerns about the guidance provided to staff to support the decision 
making process about when not to perform cardiopulmonary resuscitation (CPR) in prisons, 
and in particular the inclusion of rigor mortis in the list of conditions which provide evidence 
that death has occurred.  You are concerned that there is potential for prison officers (who 
have not been trained to recognise rigor mortis) mistakenly to assess an individual as being 
in such a state, and to miss the opportunity to undertake CPR and thereby possibly to 
prevent death.  You note that this risk is mitigated by the presence of healthcare staff who 
attend such incidents and can advise prison officers on the condition of the prisoner.  
However, in prisons without 24 hour healthcare staffing, and where there is therefore no 
such mitigation, you believe the guidance to be inappropriate. 

I am grateful to you for raising this concern.   

In response, we have revisited the guidance, and whilst it does include the line that “staff 
who are not able to tell if rigor mortis has set in must start resuscitation until advised by a 
healthcare professional”, we acknowledge that this is less prominent than it could be, and 
that it is not clear that there is no expectation that prison staff should be able to make this 
judgement.   

We have also taken advice from Resuscitation Council UK (RCUK) who have confirmed 
that training and clinical experience are required reliably to diagnose irreversible death 
based on the presence of rigor mortis, and that this is outside the scope of first aid training.  
For this reason RCUK encourages rescuers to start CPR and wait for more experienced 
help (e.g. a paramedic) to arrive to make decisions about stopping CPR in situations in 

 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 which the diagnosis of irreversible death is uncertain.  In their view, our guidance is more 
akin to the guidance provided to ambulance staff, who, unlike prison staff, receive training 
on it and develop experience in its use. 

In the light of your concerns and the advice from RCUK we will move quickly to undertake a 
review of our guidance to address this point and issue a revised version as soon as 
possible. 

Yours sincerely 

    Director General Operations

Related reports

Other reports by Peter Nieto

See all →

More reports categorised “Alcohol, drug and medication related deaths”

See all →

Track Alcohol, drug and medication related deaths

See every Prevention of Future Deaths report matching Alcohol, drug and medication related deaths, and how often a new one appears.

What would an alert for this have sent me? Search the full text

Free to try — the preview shows the real matches and how many arrived in the last 12 months. Your first email alert is free.

These reports are published by the Chief Coroner's office at judiciary.uk and are © Crown copyright. The text here is reproduced from the published PDF so it can be searched. If something on this page is wrong, or you are a person named in it and want it reviewed, email drcjar@gmail.com and we will act promptly.