McAdoo v. Martin, No. 17-1952 (8th Cir. 2018)Annotate this Case
The Prison Litigation Reform Act's (PLRA) gatekeeper function against frivolous suits does not require a prison inmate to make a showing of a physical injury caused by an unconstitutional act. Rather, in the Eighth Amendment context, in order to recover compensatory damages, the PLRA requires a showing of harm caused by some unconstitutional conduct that amounted to deliberate indifference and an accompanying showing of physical injury.
In this prisoner medical needs case, plaintiff appealed the district court's judgment awarding him only nominal and no punitive damages. The district court held that defendants violated plaintiff's Eighth Amendment rights by their deliberate indifference to his serious medical needs while he was in their custody, but that the PLRA precluded plaintiff's recovery of compensatory damages because he failed to meet 42 U.S.C. 1997e(e)'s physical injury threshold.
The Eighth Circuit held that plaintiff's severe pain resulted from an actual physical injury when an officer's takedown move broke his shoulder, and thus plaintiff met the PLRA's physical injury requirement under section 1997e(e). Therefore, the court reversed and remanded with instructions for the district court to calculate compensatory damages that result from the pain differential, if any, that plaintiff experienced from having to take non-prescription pain relievers instead of the ten prescribed hydrocodone tablets. Finally, the district court did not abuse its discretion by denying punitive damages.