AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law for Jails, Prisons and Detention Facilities
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Freedom Restoration Act did not subject the federal government to lawsuits
for damages. Claims for injunctive relief by Jewish prisoners claiming
religious discrimination were also moot because of their release from confinement.
Webman v. Fed. Bureau of Prisons, No. 05-5031, 2006 U.S. App. Lexis 7540
(D.C. Cir.). [2006 JB May]
New York Court of Claims upholds award of $350,000 for conscious pain and suffering to estate of deceased inmate who died of a prescription drug overdose in case where prison officials were found to have been negligent in allowing him to have more than one pill at a time in his cell. Prisoner's death after overdose took thirteen days to occur, and he underwent numerous invasive medical procedures during that interval. Court also upholds, however, the failure to award any economic damages, when the decedent had a "limited work history," and had never earned enough money in any year to require him to file a tax return. $25,000 also awarded to inmate's mother for her suffering based on correctional officials' failure to notify her, as the inmate's chosen relative, when her son was admitted to a hospital outside of the prison during a weekend, as required by the correctional department's policy. Arias v. State of New York, No. 97942, 795 N.Y.S.2d 855 (Ct. Cl. 2005). [N/R]
Federal appeals court upholds jury's award of $29 million in compensatory and $27.5 million in punitive damages against two deputy sheriffs for causing pre-trial detainee's death through use of excessive force. Failure to show that the death was caused by any official policy or custom, or by deliberate indifference to a widespread pattern of violation of jail policies, required summary judgment on claims against county sheriff. Mere number of uses of pepper spray did not show that it was being misused. Estate of Moreland v. Dieter, No. 03-3734, 2005 U.S. App. Lexis 743 (7th Cir.). [2005 JB Mar]
While prisoner successfully proved that prison security director improperly put him in segregation in retaliation for filing "too many" complaints and grievances, in violation of his First Amendment rights, under the Prison Litigation Reform Act, he was not entitled to an award of compensatory damages in the absence of physical injury, but only $1 in nominal damages. Appeals court also upholds the decision not to award punitive damages, since the defendant acted out of "frustration," rather than with an "evil motive," and upholds application of PLRA section to limit attorneys' fee award in the case to $1.50. Royal v. Kautzky, No. 02-3446, 375 F.3d 720 (8th Cir. 2004). [2004 JB Oct]
Prisoner was properly awarded $820,000 in damages against county for failure to protect him from physical assault by another inmate who he had helped imprison by cooperating in law enforcement narcotics investigation. Federal appeals court rejects argument that damages were excessive, and upholds trial court's reduction of jury's prior award of $1,610,000. Rangolan v. County of Nassau, #03-7367, 370 F.3d 239 (2nd Cir. 2004). [2004 JB Sep]
Prisoner was properly awarded $1,500 in compensatory damages for allegedly being left in restraint chair for long periods of time, and $500 for alleged excessive use of force against him, but trial court properly did not award punitive damages in light of fact that the prisoner admitted disobeying orders, and that the facility had not developed policies governing the use of the restraint chair. Guerra v. Drake, #03-3137, 371 F.3d 404 (8th Cir. 2004). [2004 JB Sep]
Correctional officer was properly awarded $250,000 on his counterclaim against prisoner even though this exceeded the damages requested, in light of the unprovoked nature of the prisoner's attack and the seriousness of the "life-threatening" injuries suffered by the officer. Douglas v. McCarty, #03-6776, 87 Fed. Appx. 299 (4th Cir. 2003). [N/R]
Correctional officers assessed $15,000 in compensatory and $30,000 in punitive damages for allegedly using excessive force to restrain 60-year-old prisoner after refusing to look at his written medical restriction offered in explanation for why he was sitting rather than standing in medical clinic's waiting area. Jackson v. Austin, 241 F. Supp. 2d 1313 (D. Kan. 2003). [2003 JB Jun]
299:163 Award of $10 in damages to prisoner for violation of his religious right to receive a pork-free diet could be set off against his liability to the county for costs arising out of the same lawsuit; federal court does not reach restitution issue. Rinaldo v. Corbett, No. 99-10801, 256 F.3d 1276 (11th Cir. 2001).
298:155 Trial judge's award of $1.8 million in damages for suicide of pre-trial detainee in federal jail overturned; suicide after six months of incarceration was not foreseeable when prisoner had no known prior history of suicide attempts or thoughts; award of $1.6 million for pain and suffering while hanging to death was excessive when no reasoning for the award was offered by the court. Jutzi- Johnson v. United States, #00-2411, 263 F.3d 753 (7th Cir. 2001).
298:154 Correctional officer was liable for $1,000 in compensatory damages and $500 in punitive damages for striking prisoner in the face three times following a verbal argument about proper sign-in procedures. Romaine v. Rawson, 140 F. Supp. 2d 204 (N.D.N.Y. 2001).
297:137 Federal court overturns $500,000 jury award against county in prisoner's claim of excessive force by jail detention officers; failure to specifically train officers that they were prohibited from standing on an detainee's back in an effort to restrain him did not constitute a "glaring" omission showing that county was deliberately indifferent; size of verdict also found excessive. Lewis v. Board of Sedgwick County Commissioners, 140 F. Supp. 2d 1125 (D. Kan. 2001).
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