Walker v. Schult, No. 20-2415 (2d Cir. 2022)
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Defendants, federal prison officials, appealed a district court’s judgment awarding former prisoner $20,000 for mental and emotional injury requesting damages pursuant to Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971), for his imprisonment in overcrowded conditions that posed a substantial risk of serious damage to his health or safety, to which Defendants were deliberately indifferent, in violation of his rights under the Eighth Amendment to the Constitution.
The Second Circuit reversed the judgment and remanded for dismissal of Plaintiff’s complaint. The court held first that the PLRA provision in 42 U.S.C. Section 1997e(e) precludes a prisoner's recovery of compensatory damages for mental or emotional injury resulting from his conditions of confinement absent a showing of physical injury. Next, Section 1997e(e) makes physical injury an element of such a claim for mental or emotional injury and is not an affirmative defense that would be subject to waiver if not presented in Defendant's answer. In light of Section 1997e(e), the jury's finding that Plaintiff failed to prove that the prison conditions of which he complained caused him physical injury precluded an award to him of compensatory damages for such mental or emotional injury as the jury found he suffered based on the conditions it found existed.
Moreover, even if the jury's findings of fact warranted a conclusion that Plaintiff’s Eighth Amendment rights were violated by deliberate indifference to cruel and unusual psychological punishment caused by overcrowding, Defendants are entitled to qualified immunity from such an award.
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