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