Washington v. Denney, No. 17-2747 (8th Cir. 2018)
Annotate this CasePlaintiff 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.
Court Description: Smith, Author, with Wollman and Loken, Circuit Judges] Prisoner case - Prisoner civil rights. In action alleging defendants were deliberately indifferent to plaintiff's serious medical needs by failing to take reasonable steps to abate the risk secondhand smoke posed to him because of his asthma and other respiratory conditions, a jury found for plaintiff and awarded him compensatory and punitive damages; held, sufficient evidence exists to support the jury's verdict that defendants violated plaintiff's Eighth Amendment rights and its award of compensatory damages; however the award of punitive damages is not supported by sufficient evidence that the defendants were motivated by evil motives or intent or that they showed callous indifference to plaintiff's Eighth Amendment rights, and the punitive damage award is set aside.
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