Cowart v. Erwin, No. 15-10404 (5th Cir. 2016)
Annotate this CasePlaintiff, a former prisoner, filed suit against four Dallas County Jail detention officers under 42 U.S.C. 1983 and state law. Plaintiff claims that the officers beat him without justification. The jury found Special Response Team Officer Erwin liable as to all claims, and awarded both compensatory and punitive damages. The court concluded that the district court did not abuse its discretion in concluding that plaintiff complied with the Prison Litigation Reform Act's (PLRA), 42 U.S.C. 1997(e)(a), exhaustion requirement; sufficient evidence supports the jury's verdict finding Erwin liable for excessive force; the court need not address Erwin’s challenges to the jury’s findings of section 1983 bystander liability or assault under state law, as Erwin’s liability for excessive force is alone sufficient to uphold the verdict; the court rejected Erwin's challenges to the jury's award of damages; and the result in this case does not reflect a miscarriage of justice and the district court acted within its discretion in denying Erwin’s new trial motion. Accordingly, the court affirmed the judgment.
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