AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law for Jails, Prisons and Detention Facilities
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An inmate claimed
that he was severely beaten by Special Operations Group personnel who were
in the process of securing the prison during a lockdown that followed an
inmate's killing of a guard. Evidence of the prisoner's injuries, including
photographs, his own testimony, and the testimony of an ombudswoman, supported
the jury's decision to award the plaintiff compensatory and punitive damages
against a prison administrator who was allegedly deliberately indifferent
to a serious risk of harm to him. The award totaled $45,000 in compensatory,
and $200,000 in punitive damages. Further proceedings were needed, however,
to reconsider the amount of the punitive damage award, which the court
stated might be supportable, but which merited a "hard look,"
which it believed was not done by the court below following the trial.
Mejias v. Roth, #07-3913, 2009 U.S. App. Lexis 12767 (Unpub. 3rd Cir.).
Prisoner was not entitled to a jury instruction on punitive damages in his lawsuit contending that correctional officials' serving of a pork substitute showed an unlawful preference for Muslim and Jewish prisoners since they rejected his own Hindu religious request for a modified diet. Even if his allegations were true, they did not allege conduct amounting to evil intent or reckless or callous indifference to his constitutional rights, and he was therefore not entitled to punitive damages. The jury awarded him $629 in damages against one defendant and $1 against a second, on equal protection claims. Patel v. Wooten, No. 07-1030, 2008 U.S. App. Lexis 3216 (10th Cir.).
New York Commissioner of Corrections and deputy prison superintendent were not entitled to qualified immunity on prisoner's claim that they conspired to violate his civil rights in a lawsuit brought by a prisoner over the alleged failure to protect him from attacks by other prisoners. Jury awarded a total of $150,000 in compensatory damages and $7.5 million in punitive damages, but a new trial was ordered on the punitive damages issue. Britt v. Garcia, No. 05-0641, 2006 U.S. App. Lexis 18795 (2d Cir.). [2006 JB Sep]
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 $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]
U.S. Supreme Court holds that a punitive damages award of $145 million was excessive in a case where the compensatory damages were $1 million. Such a disproportionate award of punitive damages violates the Due Process Clause of the Fourteenth Amendment. Courts reviewing punitive damages should consider: (1) the degree of reprehensibility of the defendant's misconduct, (2) the disparity between the actual or potential harm suffered by the plaintiff and the punitive damages award, and (3) the difference between the punitive damages awarded by the jury and the civil penalties authorized or imposed in comparable cases. State Farm Mutual Automobile Insurance Co. v. Campbell, #01-1289, 123 S. Ct. 1513 (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]
Strip search of male prisoner in the presence of female correctional officers could constitute cruel and unusual punishment in violation of the Eighth Amendment if female officers were, as prisoner alleged, "invited spectators" and the search was carried out in a manner designed to humiliate and demean him. Federal appeals court rules that provision of Prison Litigation Reform Act barring claims for mental or emotional injuries without a showing of physical injury did not apply, in this case, to bar claims for nominal or punitive damages. Calhoun v. Detella, #98-2894, 319 F.3d 936 (7th Cir. 2003). [2003 JB Jun]
Oregon statute requiring that 60% of any punitive damage award go to a state fund benefiting crime victims does not violate the state constitution. Oregon Supreme Court finds that the statute, Ore. Stat. 18:540 unambiguously applies to federal cases arising from state law. While the case did not involve correctional or law enforcement parties, the reasoning would apply in such cases. DeMendoza v. Huffman, No. SC S48430, 51 P.3d 12232 (Ore. 2002). [N/R]
U.S. Supreme Court rules that punitive damages may not be awarded in private lawsuits under provisions of the Americans With Disabilities Act (ADA) and Rehabilitation Act prohibiting disability discrimination by public entities or the recipients of federal funding. Decision overturns $1.2 million award against city for failure to provide wheelchair restraints in a vehicle in which a wheelchair-bound detainee was transported and injured. Barnes v. Gorman, #01-682, 122 S. Ct. 2097 (2002). [2002 JB Aug]
County board of supervisors could be sued, overcoming qualified immunity, based on alleged prior decisions in bad faith to indemnify county sheriffs from punitive damage awards which purportedly proximately caused subsequent violations of plaintiff's constitutional rights. Navarro v. Block, #99-55623, 250 F.3d 729 (9th Cir. 2001). [N/R]
U.S. Supreme Court to rule on the issue of whether punitive damages may be awarded against a municipality in a lawsuit for damages brought under Section 504 of the Rehabilitation Act or Section 202 of the Americans With Disabilities Act. Barnes v. Gorman, #01-682, cert. granted, 122 S. Ct. 864 (2002). [2002 JB Mar]
Jury properly awarded $1.034 million in compensatory damages to wheelchair-bound arrestee injured while being transported in van that was not equipped with wheelchair restraints; appeals court rejects trial court's setting aside of jury's punitive damages award of $1.2 million, however, ruling that punitive damages are available in disability discrimination cases for denial of public services. Gorman v. Easley, #00-1029, 257 F.3d 738 (8th Cir. 2001). [2002 JB Jan]
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).
298:151 Private corporation providing medical care to detainees in county correctional facility was not to be treated as a "municipality" in detainee's federal civil rights lawsuit; plaintiff could seek punitive damages and need not show a policy or custom of the corporation caused the alleged deprivation to establish liability. Segler v. Clark County, 142 F. Supp. 2d 1264 (D. Nev. 2001).
297:139 Prisoner who was barred, by Prison Litigation Reform Act, from receiving compensatory damages for mental distress from failure to receive kosher diet could still be awarded punitive damages by a jury; appeals court orders new trial on punitive damages alone. Searles v. Van Bebber, No. 99-3076, 251 F.3d 869 (10th Cir. 2001).
290:29 Woman arrested for misdemeanor who was subjected to strip and body cavity searches without any reasonable suspicion that she possessed weapons or contraband was properly awarded $19,465 in compensatory damages, but city could not be held liable for the $5 million in punitive damages that the jury awarded. Ciraolo v. City of N.Y., #99-7550, 216 F.3d 236 (2nd Cir.), cert. denied, 121 S. Ct. 484 (2000).
EDITOR'S NOTE: On remand to the trial court, it also awarded the plaintiff's motion for attorney's fees and costs of $19,116.45, reflecting the costs and attorneys' fees incurred before the defendants made a pre-trial offer of judgment of $25,000 plus reasonable attorneys fees. This offer was made formally under Federal Rule of Civil Procedure 68. Because the plaintiff did not accept it, and was ultimately awarded a smaller amount of damages ($19,645) after appeal, their right to recover additional attorneys' fees and costs following that rejection were cut off. Further, the defendants were awarded $8,038.40 for necessary costs they incurred after the rejection of their offer. Ciraolo v. City of New York, 2000 U.S. Dist. LEXIS 14940 (S.D.N.Y. 2000).
290:28 Female detainee compelled to strip and dance for male and female inmates and guards was properly awarded $350,000 in compensatory damages; District of Columbia, as a municipality, could not, however, be held liable for $5 million in punitive damages. Daskalea v. District of Columbia, #98-7207, 227 F.3d 433 (D.C. Cir. 2000).
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