AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law
for Jails, Prisons and Detention Facilities


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Damage Awards

     277:11 Correctional officer violated prisoner's First Amendment rights by placing him in administrative segregation for three days in retaliation for filing grievances against him; appeals court rules that nominal damage award of $1 was inadequate, and that trial court should increase this and also consider awarding punitive damages against officer. Trobaugh v. Hall, #98-4031, 176 F.3d 1087 (8th Cir. 1999).
     277:11 Correctional officer violated prisoner's First Amendment rights by placing him in administrative segregation for three days in retaliation for filing grievances against him; appeals court rules that nominal damage award of $1 was inadequate, and that trial court should increase this and also consider awarding punitive damages against officer. Trobaugh v. Hall, #98-4031, 176 F.3d 1087 (8th Cir. 1999).
     237:131 U.S. Supreme Court rules that an award of punitive damages which was 500 times the size of the compensatory damages awarded by a jury was "grossly excessive" and constitutionally violative of the Due Process Clause of the Fourteenth Amendment. BMW of North America, Inc. v. Gore, 116 S.Ct. 1589 (1996).
     237:131 U.S. Supreme Court rules that an award of punitive damages which was 500 times the size of the compensatory damages awarded by a jury was "grossly excessive" and constitutionally violative of the Due Process Clause of the Fourteenth Amendment. BMW of North America, Inc. v. Gore, 116 S.Ct. 1589 (1996).
     U.S. Supreme Court holds that courts should dismiss federal civil rights suits seeking damages when a judgment in favor of the plaintiff necessarily implies the invalidity of the plaintiff's criminal sentence, but that sentence has not already been overturned. 114 S.Ct. 2364 (1994).
     Oregon state constitutional provision prohibiting judicial review of jury awards of punitive damages in most cases violates the due process clause of the Fourteenth Amendment, U.S. Supreme Court holds. Honda Motor Co., Ltd. v. Oberg, 114 S.Ct. 2331 (1994).
     U.S. Supreme Court holds that $10 million punitive damage award did not violate due process. Pacific Mutual Life Ins. Co. v. Haslip, 499 U.S. 1 (1991), a claim the court rejected.
     Federal Tort Claims Act prohibition of award of "punitive damages" against U.S. government does not bar awards for future medical expenses or for loss of enjoyment of life. Molzof v. U.S., 112 S.Ct. 711 (1992).
     Punitive damages are not, per se, a violation of due process, but Supreme Court indicates that "extreme results" may be "unacceptable" under due process. Pacific Mut. Life Ins. Co. v. Haslip, 111 S.Ct. 1032 (1991).
     Prisoner could not sue state prison warden in his official capacity for damages under federal civil rights law. Wilson v. Brown, 889 F.2d 1195 (1st Cir. 1989).
     Court rejects eighth amendment challenge to punitive damage awards. Browning-Ferris Industries of Vermont, Inc. v. Kelco Disposal, Inc. 109 S.Ct. 2909 (1989).

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