King v. Zamiara, No. 13-1777 (6th Cir. 2015)
Annotate this CaseAfter King, a Michigan Department of Corrections (MDOC) inmate, participated in a class-action lawsuit challenging personal property policies at MDOC facilities (Cain litigation), prison officials transferred him to a prison with a higher security classification and more restrictive conditions. King filed suit under 42 U.S.C. 1983. The Sixth Circuit held that prison officials were liable for retaliating against King for his First Amendment-protected conduct, participating in the Cain litigation and assisting other petitioners to file grievances. On remand, the district court granted compensatory damages and awarded attorney fees, but denied punitive damages and injunctive relief. The Sixth Circuit affirmed the denial of injunctive relief and the award of punitive damages, but otherwise vacated and remanded, first holding that 42 U.S.C. 1997e(e), the Prison Litigation Reform Act, does not foreclose claims that allege violations of First Amendment-protected rights as injuries, even if those violations did not cause physical harm. The district court properly applied the PLRA to calculate the appropriate award of attorney fees, but abused its discretion in denying punitive damages and misapplied the PLRA’s attorney fees provision when it failed to charge a portion of the attorney fees against King’s judgment.
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