Lunsford v. Shy (Signed Opinion)Annotate this Case
The Supreme Court affirmed the order of the circuit court denying Petitioners' Rule 50(b) motion for judgment as a matter of law, Rule 59(a) motion for a new trial, and Rule 59(e) motion to alter or amend the judgment, as provided for by the West Virginia Rules of Civil Procedure, holding that the circuit court did not err.
Respondent filed a complaint alleging that Petitioners, two correctional officers, used excessive force against him. The jury found that Petitioners used excessive force on Respondent and committed the civil tort of battery on Respondent. The jury award compensatory damages of $0 and punitive damages of $4,500. Petitioners filed a Rule 50(b) motion for judgment as a matter of law and motions pursuant to Rules 59(a) and (e) for a new trial and/or to alter or amend the judgment, arguing that there was no reasonable relationship between the compensatory damages and punitive damages award. The circuit court denied the motions. The Supreme Court affirmed, holding that the circuit court did not err in (1) allowing punitive damages to be recovered by Respondent without an accompanying award of compensatory or nominal damages; and (2) failing to apply the provisions of the Prison Litigation Reform Act, 42 U.S.C. 1997e, to Petitioners.