Hicks v. Dahmer: Inside the 1992 $10 Million Wrongful Death Lawsuit - PART 1
The case wasn’t only about Jeff; it implicated his entire family.
Welcome to this gripping three-part series as we dive into the mysterious case of Steven Hicks, where we discover where the Jeffrey Dahmer story began, unravel the conflicting circumstances, and uncover the shocking details of a revealing civil wrongful death lawsuit.
During my investigation, something fascinating came to light shortly after the passing of Lionel Dahmer, Jeff’s father, in December 2023. In March 2024, I uncovered a 1992 Allstate Insurance claim letter—and yes, I have the original, complete with coffee stains!
As someone who specializes in exposing insurance fraud, I couldn’t resist uncovering the story behind it. Let’s just say, things got interesting.
This incredible discovery sheds fascinating light on the true events surrounding Steven Hicks in 1978.
On August 28, 1992, Steven Hicks’ family took a bold step in their pursuit of justice, filing a civil lawsuit against four individuals: Jeffrey Dahmer, his parents Lionel Dahmer, Joyce Dahmer, and step-mother Shari Dahmer. The lawsuit accused them of wrongful death, survival action, intentional and negligent infliction of emotional distress, negligence, and loss of consortium.
Additional allegations were leveled specifically at Lionel, Joyce, and Shari Dahmer, including negligent entrustment and negligence. The case took an unusual turn when Allstate Insurance became involved, as Lionel’s homeowners’ insurance policy (Allstate Deluxe Homeowners Policy No. 026502251) offered liability protection. Home insurance policies commonly cover accidental injuries to non-residents while on the property.
This legal battle officially began when Martha Hicks filed the wrongful death lawsuit in the Summit County Court of Common Pleas, Ohio, under case number CV-1992-08-3291. The Hicks family's fight for accountability became an extraordinary chapter in the aftermath of a tragic story.
The question is, why was Shari Dahmer part of the lawsuit? It’s worth pointing out that when Steven Hicks reportedly died in June 1978, Shari wasn’t even married to Lionel Dahmer yet—their wedding happened later that year in December. So, why is she involved at all? It’s a strange twist, especially since she had no connection to Jeff or any responsibility for him during that time, despite the allegations.
To really grasp what this lawsuit means, we need to dive into the legal context behind it. Bear with me—I’m going to break it all down for you!
Understanding the Legal Terms
Below are the legal definitions for wrongful death, survival action, intentional and negligent infliction of emotional distress, negligence, loss of consortium, and most crucially, negligent entrustment.
These definitions are readily available online through sources such as ‘‘Wrongful Death’’ on Wex by the Legal Information Institute (cornell.edu), ‘‘Differences Between Wrongful Death Claims and Survival Actions’’ (jsberrylaw.com), and the document ‘‘Negligent Entrustment’’ (viorstlaw.com):
Wrongful Death
Wrongful death occurs when a person’s life is taken due to someone’s negligent or intentional actions, leaving family members and dependents to seek justice through a civil lawsuit. What’s important to know is that a wrongful death claim can be filed even if the responsible party faces criminal charges—or isn’t found guilty in a criminal trial. That’s because civil cases have a lower burden of proof, allowing families another path to accountability.
These lawsuits are governed by state laws, which define who can file the claim and what damages can be awarded. Typically, spouses and children are eligible, but some states include parents, siblings, and other dependents as well.
The goal? To compensate families for the financial and emotional toll of their loss. Damages often cover lost income, expected future earnings, and the family’s level of dependence on the deceased. In some cases, juries may also award compensation for funeral costs, pain and suffering endured by the deceased, and emotional harm to the family.
In tragic cases where the death was caused by reckless or intentional behavior, some states even allow punitive damages to be awarded—sending a powerful message about accountability.
Survival Action
A survival action is also a type of personal injury lawsuit that is filed on behalf of the victim and involves damages that the deceased individual would presumably have been entitled to had he or she survived their injuries.
This type of legal action is usually filed in situations where a victim is injured by another party’s negligence, but survives the initial event only to succumb to their injuries later.
It’s also used in medical malpractice lawsuits involving a gross medical oversight, surgical mistakes, or misdiagnosis that later leads to a patient’s untimely death. The greater the period of time between the initial injury and death, the stronger the case that the deceased individual’s family has for a survivor action lawsuit.
Intentional Infliction of Emotional Distress (IIED)
Intentional infliction of emotional distress (IIED) is a tort (a tort is a civil wrong that causes someone to experience loss or harm) that occurs when one acts in a manner that intentionally or recklessly causes another to suffer severe emotional distress, such as issuing the threat of future harm.
Negligent Infliction of Emotional Distress (NEID)
NEID is a legal claim that addresses emotional distress caused by someone’s negligent actions. Unlike intentional infliction of emotional distress (IIED), NEID laws vary widely between states, making it an area of law with plenty of grey areas.
Negligence
Negligence is when someone fails to act with the care or responsibility expected in a given situation, leading to harm. In tort law, negligence covers cases where carelessness causes damage, sometimes with unique or extenuating circumstances playing a role.
The core concept of negligence is that people should exercise reasonable care in their actions, by taking account of the potential harm that they might foreseeably cause to other people or property.
When someone suffers a loss due to another person’s negligence, they may have the right to seek compensation for the harm done. This could mean recovering damages for physical injuries, property damage, emotional distress, or financial setbacks.
Negligence cases are often broken down into a five-step process (the elements of negligence):
· Was there a duty of care?
· Was it breached?
· What caused the harm—both directly and indirectly?
· And finally, what damages resulted?
Each step plays a crucial role in determining justice and accountability.
Loss of Consortium
Loss of Consortium refers to the loss or damage of the emotional and intangible benefits that come with a close relationship. When this loss is caused by someone’s wrongful actions, the affected loved ones may have the right to seek compensation for the emotional pain and impact on their relationship.
Negligent Entrustment
Finally, this term is absolutely key when it comes to understanding the lawsuit.
Negligent Entrustment is a cause of action in United States tort law which arises where one party (‘‘the entrustor’’) is held liable for negligence because they negligently provided another party (‘‘the entrustee’’) with a dangerous instrumentality, and the entrusted party caused injury to a third party with that instrumentality.
The cause of action most frequently arises where one person allows another to drive their automobile.
Did you know that one of the first cases of Negligent Entrustment stemmed from a ‘‘joyriding’’ lawsuit (the 1915 Mississippi case of Winn v. Haliday)? It raises an intriguing question: What exactly did Lionel Dahmer, Shari Shinn, and Joyce Dahmer entrust Jeff with—and at what cost?
Allegations That Defy Logic
The following press article on the lawsuit stated that Jeff Dahmer's parents ‘‘knew or should have known’’ that he was ‘‘destined to cause injury and death to others’’
The lawsuit also names Shari Dahmer as a defendant, but it's important to note that she wasn’t Jeffrey Dahmer’s parent. In June 1978, when the incident with Steven Hicks allegedly took place, Lionel Dahmer was still married to Jeff’s mother, Joyce. Their divorce wasn’t finalized until July 1978. Just a few months later, in December, Lionel remarried and tied the knot with Shari Shinn, as she was known at the time.
So when Steven Hicks died, Shari Dahmer wasn’t even Lionel Dahmer’s wife yet—she was just his girlfriend. She wasn’t living in the family home on Bath Road either; she was staying with Lionel at a nearby motel.
And yet, she’s listed as a defendant in the wrongful death lawsuit, accused of negligence and negligent entrustment for Jeff’s actions. The question is—why?
This was more likely due to her involvement as an accessory, so implicating her in the wrongful death lawsuit with claims of parental responsibility was misleading.
Court Rules in Favor of Hicks Family
Judge James R. Williams ruled in favor of the Hicks family, deeming Lionel Dahmer, Joyce Dahmer, and Shari Shinn Dahmer guilty of the allegations. The decision raises the question of how the judge determined that Jeff's parents, along with Shari Shinn Dahmer, ‘‘knew or should have known’’ that Jeff was ‘‘deviant and destined to cause injury and death to others.’’
The specifics of the ruling remain unclear, but it is worth considering Jeffrey Dahmer’s remarks to forensic psychiatrist Dr. Frederick Fosdal, who evaluated Jeff.
‘‘First mistake that led up to all this. Had I driven past, all this would not have happened.’’
It’s a striking statement, especially coming from someone who, according to the official story, had been consumed by fantasies of corpses and murder since the age of 15.
Did Steven Hicks’ parents ever uncover the full truth about what happened to their son? Could it be that Steven was accidentally injured, leading Jeffrey Dahmer to panic instead of calling for help? This theory raises intriguing possibilities, including the potential for a wrongful death lawsuit, where the burden of proof is lower than in criminal cases.
Jeffrey Dahmer's $10 Million Judgment: Why Did His Parents Escape Liability?
An additional examination of the case record reveals that a judgment was granted solely against Jeff for $10,000,000.00 (Source: Summit County Court of Common Pleas, Ohio, under case number CV-1992-08-3291).
It is important to note that Judge James R. Williams presided over both the criminal and civil cases involving Steven Hicks (Source: Summit County Court of Common Pleas, Ohio, under cases number CV-1992-08-3291 and CR-1991-09-2090, Case Detail (summitoh.net).
The excerpt states:
JE 1760-119 MARTHA HICKS, ADMINISTRATRIX OF THE ESTATE OF STEVEN HICKS GRANTED JUDGMENT AGAINST JEFFREY DAHMER ONLY, IN THE AMOUNT OF $10,000,000.00. JRW
Allstate Insurance addressed the question of whether they settled the claim in their response, as explained in the letter above. The claim was denied on the basis that insurance policies do not cover intentional acts (such as murder), which is a fundamental principle of insurance—except in the case of life insurance, where the policy is designed to pay out upon inevitable death. Additionally, the claim was denied due to a failure to notify the insurer in a timely manner, which is a crucial policy requirement.
But while the case suggests intent behind the act, there’s no evidence to back up this allegation...
Surprisingly, even after being found guilty in the lawsuit, Lionel, Shari, and Joyce faced no extra penalties. The $10m judgment was made solely against Jeff, as previously mentioned.
What’s even more intriguing is that Jeff was already 18 at the time of the Hicks incident, meaning parental civil liability should have ended. Yet, his parents and Shari were still accused—and found guilty—in their roles as parents.
However, under Ohio law, there’s an interesting exception to this rule: parents can still be held liable for an adult child under the ‘‘Family Car’’ doctrine. Here’s what that means, as explained in this excerpt from Parental Civil Liability - FindLaw:
‘‘Parental Civil Liability in Selected States:
Ohio: The state may find a parent liable for willful misconduct of their child that causes property damage, assaults another with force likely to cause great bodily harm, or results in theft from another. State law caps damages at $10,000 per act, plus court costs. State law caps damages at $15,000 per act, plus attorney fees and court costs. A parent may be liable for negligent or willful misconduct of their child caused by a motor vehicle accident. State law does not cap damages under state law for motor vehicle accidents.
There is also parental liability through the Family Car Doctrine, which holds the owner of a family car legally responsible for any damage caused by a family member when driving, if the owner knew of—and consented to—the family member's use of the car. About half of the states apply this doctrine, known under the broader theory of negligent entrustment. Thus, even if a parent doesn't have a minor household member listed on the auto insurance policy, under the family car doctrine, the parent remains liable.’’
Did you catch the mention of negligent entrustment in the definition above?
Given the $10m judgment, which surpasses the typical cap except for motor vehicle accident cases, it implies this judgment involves such a case. Moreover, the lack of a judgment against the parents, despite their guilty verdict, implies that a plea agreement was made to avoid imprisonment and/or the obligation to pay financial compensation.
This agreement likely tackled two main concerns: concealing a death and negligent entrustment. It may also have also involved engaging with the bizarre “Milwaukee Cannibal” narrative.
What are your thoughts on this?
Don't miss Part 2 of this series, where we dive deeper into the questionable identification of Steven Hicks and the conflicting stories behind his disappearance. Stay tuned!
This is painfully revealing: "However, under Ohio law, there’s an interesting exception to this rule: parents can still be held liable for an adult child under the ‘‘Family Car’’ doctrine."
The facts don't fit the narrative of a man who killed Hicks intentionally, not by a long shot! And nobody would ever known about this if you hadn't found this document, that's for sure!! This is the best find in this case.
Why didn't the court indicate the name of the vehicle and its number in the documents? Why didn't they write directly that it was a car?