S.D. was in his mid-30's and the father of two children.  He was admitted to a nursing home in the City of St. Louis, Missouri after suffering from a brain injury that left him totally dependent upon others for his care.  Although unable to care for himself or communicate, S.D. was alert and would track individuals in his room with his eyes.  During the course of his residency, the nursing home facility was responsible for providing all of his activities of daily living, including bathing, feeding him through a tracheotomy tube, toileting, as well as turning and repositioning him and preventing the development of bed sores.

Within six months of entering the nursing home facility, S.D. had developed several bed sores all over his body.  Specifically, bed sores had developed on his sacrum, coccyx, both hips, left elbow, both knees, left ankle, right foot, and both ears.  He also lost a great deal of weight and was rarely bathed.

His father, who visited every day, repeatedly asked facility staff members to keep his son clean and to give him the care they were supposed to provide.  His father even tested facility employees without their knowledge.  For example, with a pen, he marked an "x" on the corner of his son's bed sheet and dated it.  Every day for four days he was told that his son's bed sheets had been changed.  After the fourth day, he brought the charge nurse to his room and showed her the marking he had made on the sheet, proving that facility staff had lied to him.

Deposition testimony of numerous facility employees revealed that few knew their designated job responsibilities and fewer still were aware of key facility policies and procedures.  One fact on which many employees did agree, however, was that the facility was regularly understaffed, leaving patients without much needed help.

During the course of his residency, S.D.'s bed sores increased in size and depth and worsened to the point that several became infected.  He also developed osteomylitis, which is an infection of the bone, as well as an infection at the site of his tracheotomy.  His multiple infections and bed sores eventually caused him to be taken to a local hospital.  Upon arrival at the emergency room, a hospital employee wrote the following note:

             "Nursing advised Social Services that patient arrived very