New York Jury Awards $1,400,006 to Former Prisoner for Beating by Guards; Punitive Damages Later Reduced
New York Jury Awards $1,400,006 to Former Prisoner for Beating by Guards; Punitive Damages Later Reduced
by David M. Reutter
A New York federal jury awarded $1,400,006 to a former prisoner in a lawsuit alleging two beatings by state prison guards. The U.S. District Court reduced the punitive damages award on a post-trial motion, cutting the total damages by almost half.
Upon returning from a medical callout on February 25, 2003 at New York’s Oneida Correctional Facility, prisoner Angel Martinez rang his dormitory’s doorbell several times to gain entry. Angered at being disturbed while he was using the bathroom, guard Scott Thompson decided Martinez would spend the night in solitary confinement. Martinez requested to see a sergeant to report that Thompson had pushed him during the confrontation.
Under the guise of wanting to discuss the matter, Thompson told Martinez to step outside. Once they were out of view of other prisoners, Thompson sounded a “Code 17” to indicate he was in trouble, then began beating Martinez. Guards Larry Sisco, Scott Myers, Thomas Novak and Donna Temple arrived and joined in the assault.
The beating was so severe that Martinez was knocked unconscious; he suffered a broken rib, a herniated intervertebral disc of his spine’s lumbar region, and defecated on himself. The guards put him in restraints and took him to solitary, where he was denied medical treatment and food during his first week. He was charged with numerous disciplinary infractions and sentenced to twenty-four months confinement in the SHU.
In a separate incident, when being returned to his cell on March 5, 2003 to inspect his property, guards Michael Duvall and Ronald LaBrague assaulted Martinez without provocation, exacerbating his injuries. On April 24, 2004 an Oneida County grand jury returned a “no bill” on criminal charges filed against Martinez related to the February 25 incident.
Martinez was released from solitary confinement after 240 days following an appellate division reversal of his disciplinary charges. He then sued. He was released from prison on December 1, 2006 while his case was pending, and was appointed pro bono counsel by the court.
The lawsuit progressed to trial and the jury reached a verdict on September 12, 2008. The jury found that Thompson and Sisco had used excessive force during the February 25, 2004 incident. It also found that Duvall and LaBrague’s use of force was excessive. The jurors determined that Thompson, Duvall and LaBrague’s actions were in retaliation for Martinez’s threat to report staff misconduct. Finally, they held that Thompson, Sisco and Meyers’ attempt to have Martinez prosecuted was malicious. The court dismissed several other defendants, and the jury found in favor of defendants Temple and Novak.
After rejecting a qualified immunity defense, the jury awarded compensatory damages of $200,000 against Thompson; $100,000 against Duvall; $50,000 against LaBrague and $150,000 against Sisco, for a total of $500,000. Nominal damages were awarded for the retaliation and malicious prosecution claims, totaling $6.00. An award of $900,000 in punitive damages was also entered.
The district court rejected the defendants’ argument that the compensatory damages were excessive, but found the punitive damages award to be “exceedingly disproportionate.” The court therefore reduced the punitive damages against Thompson, Duvall, LaBrague and Sisco to $210,000 in a December 8, 2008 order. The compensatory, nominal and revised punitive damages totaled $710,006, and Martinez accepted the remittitur in lieu of a new trial on January 16, 2009.
The district court also awarded attorney fees and costs to Martinez, in the amount of $160,485.11. He was represented by New York City attorneys Glenn D. Miller and Edward Sivin. See: Martinez v. Thompson, USDC (N.D. New York), Case No. 9:04-cv-0440-DEP.
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Related legal case
Martinez v. Thompson
| Year | 2008 |
|---|---|
| Cite | USDC (N.D. New York), Case No. 9:04-cv-0440-DEP |
| Level | District Court |
| Conclusion | Jury Verdict |
| Attorney Fees | 1,400,006.00 |
| Damages | 160,485.11 |
| Injunction Status | N/A |