Washington v. Denney, No. 17-2747 (8th Cir. 2018)Annotate this Case
Plaintiff filed suit against corrections officials at Crossroads Correctional Center for violation of his Eighth Amendment rights under 42 U.S.C. 1983. The Eighth Circuit affirmed the jury's finding that the officials were deliberately indifferent to plaintiff's serious medical need by failing to take reasonable steps to abate the risk of harm that secondhand smoke posed to him. In this case, there was sufficient evidence to show that the officials violated plaintiff's Eighth Amendment rights by being deliberately indifferent to the fact that plaintiff's asthma was exacerbated by offenders smoking indoors. However, there was insufficient evidence to justify an award of punitive damages where plaintiff failed to show that the officials were motivated by evil motive or intent or showed callous indifference to plaintiff's rights. Therefore, the court vacated the award of punitive damages and remanded for further proceedings.