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Eighth Circuit Upholds $2,501 Retaliation Judgment Against Arkansas Prison Guard
The U.S. Court of Appeals for the Eighth Circuit has affirmed a $2,501 award to an Arkansas state prisoner who was subjected to retaliation by an Arkansas Department of Correction (ADC) guard.
On June 23, 2007, ADC prisoner Walter Haynes filed a grievance against Sgt. Patrick L. Stephenson, who had cursed him out the day before. Once Stephenson learned about Haynes’ complaint he filed a disciplinary report accusing Haynes of lying in the grievance. ADC regulations, however, prohibit guards from filing disciplinary reports against prisoners who file false grievances, and Stephenson knew that.
Haynes was initially subjected to various sanctions before the disciplinary report was dismissed. He then filed a 42 U.S.C. § 1983 action against Stephenson, alleging that the disciplinary report constituted retaliation in violation of the First Amendment.
Following a two-day bench trial, the district court found in favor of Haynes and awarded him $1 in nominal damages plus $2,500 in punitive damages. Stephenson appealed.
Because the disciplinary report was dismissed before any formal sanctions were imposed, Stephenson argued that Haynes had failed to state a cognizable claim of retaliation. The Eighth Circuit disagreed.
“[W]e have held that ‘the filing of a disciplinary charge ... is actionable under section 1983 if done in retaliation for [the inmate’s] having filed a grievance pursuant to established procedures,’” the appellate court wrote in a December 16, 2009 opinion. “Because the retaliatory filing of a disciplinary charge strikes at the heart of an inmate’s constitutional right to seek redress of grievances, the injury to this right inheres in the retaliatory conduct itself.”
Stephenson also argued that Haynes failed to show he would not have filed the disciplinary report but for Haynes’ grievance. Rejecting this argument, the Eighth Circuit noted that Stephenson had filed the report almost immediately after Haynes submitted his grievance.
Finally, Stephenson argued that the award of punitive damages was too high because his conduct was not reprehen-sible and because the ratio of punitive to nominal damages was more than 100-to-1.
The Court of Appeals dismissed both arguments, holding the district court’s finding of reprehensibility was not clearly erroneous. Further, although the punitive damages award represented a 2500:1 ratio, the Eighth Circuit concluded that Stephenson’s “willful, malicious, and deceitful conduct” supported the award. See: Haynes v. Stephenson, 588 F.3d 1152 (8th Cir. 2009).
On June 23, 2007, ADC prisoner Walter Haynes filed a grievance against Sgt. Patrick L. Stephenson, who had cursed him out the day before. Once Stephenson learned about Haynes’ complaint he filed a disciplinary report accusing Haynes of lying in the grievance. ADC regulations, however, prohibit guards from filing disciplinary reports against prisoners who file false grievances, and Stephenson knew that.
Haynes was initially subjected to various sanctions before the disciplinary report was dismissed. He then filed a 42 U.S.C. § 1983 action against Stephenson, alleging that the disciplinary report constituted retaliation in violation of the First Amendment.
Following a two-day bench trial, the district court found in favor of Haynes and awarded him $1 in nominal damages plus $2,500 in punitive damages. Stephenson appealed.
Because the disciplinary report was dismissed before any formal sanctions were imposed, Stephenson argued that Haynes had failed to state a cognizable claim of retaliation. The Eighth Circuit disagreed.
“[W]e have held that ‘the filing of a disciplinary charge ... is actionable under section 1983 if done in retaliation for [the inmate’s] having filed a grievance pursuant to established procedures,’” the appellate court wrote in a December 16, 2009 opinion. “Because the retaliatory filing of a disciplinary charge strikes at the heart of an inmate’s constitutional right to seek redress of grievances, the injury to this right inheres in the retaliatory conduct itself.”
Stephenson also argued that Haynes failed to show he would not have filed the disciplinary report but for Haynes’ grievance. Rejecting this argument, the Eighth Circuit noted that Stephenson had filed the report almost immediately after Haynes submitted his grievance.
Finally, Stephenson argued that the award of punitive damages was too high because his conduct was not reprehen-sible and because the ratio of punitive to nominal damages was more than 100-to-1.
The Court of Appeals dismissed both arguments, holding the district court’s finding of reprehensibility was not clearly erroneous. Further, although the punitive damages award represented a 2500:1 ratio, the Eighth Circuit concluded that Stephenson’s “willful, malicious, and deceitful conduct” supported the award. See: Haynes v. Stephenson, 588 F.3d 1152 (8th Cir. 2009).
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Related legal case
Haynes v. Stephenson
| Year | 2009 |
|---|---|
| Cite | 588 F.3d 1152 (8th Cir. 2009) |
| Level | Court of Appeals |
| Damages | 2,501.00 |
| Injunction Status | N/A |