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California Jury Awards Native American Prisoner $150 on Due Process Property Claim
A federal jury awarded $150 in damages to California prisoner Gregory L. Rhoades, a Native American, after finding that the property room officer at Corcoran State Prison, defendant D. Adkison, had violated Rhoades’ 14th Amendment due process rights.
In September 2000, five months after Rhoades was found guilty of assaulting an officer and sentenced to an 18-month term in the Security Housing Unit (SHU), Adkison had some of Rhoades’ property – herbs and beads that had spiritual significance to him – donated and/or destroyed.
Proceeding pro se, Rhoades filed his complaint in April 2002 in the U.S. District Court for the Eastern District of California, alleging violations of his First Amendment right to the free exercise of religion and his 14th Amendment rights to due process and equal protection. The court granted summary judgment to the defendants on Rhoades’ equal protection claim but allowed the remaining claims to go to the jury.
According to court pleadings, on August 4, 2000, while Rhoades was serving his SHU term, Adkison sent him a notice stating that prison policies prohibited him from possessing certain items and that he had 30 days to ship those items out of the prison; failure to comply meant the prohibited items would be destroyed. On September 3, 2000, Rhoades filed a grievance challenging the planned disposal of his property. Sixteen days later the contested property was donated and/or destroyed.
The defendants contended that they would not have disposed of Rhoades’ property had they been informed that he attached religious or spiritual significance to such items. That was the central disputed issue before the jury – whether Rhoades had in fact informed prison officials that his herbs and beads had religious or spiritual significance to him.
Claiming that he suffered emotional distress, Rhoades sued for $1,500 in general damages and $150,000 in punitive damages.
The jury returned a verdict in the defendants’ favor on the First Amendment claim but found in Rhoades’ favor on the due process claim (albeit awarding a paltry $150 in damages). The jurors found that the prison’s property policy, at least as it related to Rhoades’ herbs and beads, was not reasonably related to a legitimate penological interest.
The state filed a post-verdict renewed motion for judgment as a matter of law, which was denied by the district court on May 20, 2010. This case spanned over eight years from the date of its filing to its conclusion. See: Rhoades v. Alameida, U.S.D.C. (E.D.Cal.), Case No. 1:02-cv-05476-AWI-DLB; 2009 WL 5322437.
In September 2000, five months after Rhoades was found guilty of assaulting an officer and sentenced to an 18-month term in the Security Housing Unit (SHU), Adkison had some of Rhoades’ property – herbs and beads that had spiritual significance to him – donated and/or destroyed.
Proceeding pro se, Rhoades filed his complaint in April 2002 in the U.S. District Court for the Eastern District of California, alleging violations of his First Amendment right to the free exercise of religion and his 14th Amendment rights to due process and equal protection. The court granted summary judgment to the defendants on Rhoades’ equal protection claim but allowed the remaining claims to go to the jury.
According to court pleadings, on August 4, 2000, while Rhoades was serving his SHU term, Adkison sent him a notice stating that prison policies prohibited him from possessing certain items and that he had 30 days to ship those items out of the prison; failure to comply meant the prohibited items would be destroyed. On September 3, 2000, Rhoades filed a grievance challenging the planned disposal of his property. Sixteen days later the contested property was donated and/or destroyed.
The defendants contended that they would not have disposed of Rhoades’ property had they been informed that he attached religious or spiritual significance to such items. That was the central disputed issue before the jury – whether Rhoades had in fact informed prison officials that his herbs and beads had religious or spiritual significance to him.
Claiming that he suffered emotional distress, Rhoades sued for $1,500 in general damages and $150,000 in punitive damages.
The jury returned a verdict in the defendants’ favor on the First Amendment claim but found in Rhoades’ favor on the due process claim (albeit awarding a paltry $150 in damages). The jurors found that the prison’s property policy, at least as it related to Rhoades’ herbs and beads, was not reasonably related to a legitimate penological interest.
The state filed a post-verdict renewed motion for judgment as a matter of law, which was denied by the district court on May 20, 2010. This case spanned over eight years from the date of its filing to its conclusion. See: Rhoades v. Alameida, U.S.D.C. (E.D.Cal.), Case No. 1:02-cv-05476-AWI-DLB; 2009 WL 5322437.
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Related legal case
Rhoades v. Alameida
| Year | 2009 |
|---|---|
| Cite | U.S.D.C. (E.D.Cal.), Case No. 1:02-cv-05476-AWI-DLB; 2009 WL 5322437 |
| Level | District Court |
| Conclusion | Jury Verdict |
| Damages | 150.00 |
| Injunction Status | N/A |