The issue in a case brought under § 1983 is an award of punitive damages permissible without an award of compensatory damages?
Respondent was incarcerated in the Western Regional Jail. Respondent alleges that on August 24, 2015, he was taken to a visitation room by Petitioners, all of whom were correctional officers at the jail. While still in handcuffs and shackles, Respondent alleges that he was choked and beaten by Petitioners resulting in physical and emotional injuries. Respondent filed suit setting forth state law claims and a federal claim arising under 42 USC §1983. The jury found that Petitioners had, indeed, violated Respondent’s constitutional rights in violation of §1983. However, the jury awarded no compensatory damages. Against each of the three Petitioners, the jury awarded $1,500 in punitive damages--for a total of $4,500. Respondent asked to have the jury resume deliberations so it could award at least nominal damages. Petitioners objected and the trial court dismissed the jury. Judgment was later entered consistent with the verdict.
Petitioners moved for judgment as a matter of law under Rule 50(b), arguing that an award of punitive damages was improper without an award of compensatory damages. The trial court denied Petitioner’s motion, finding that under federal law “damages are presumed from the wrongful deprivation of a constitutional right.” Petitioners appeal that ruling.
Petitioners argue that federal law controls. Furthermore, “[a]s West Virginia sits in the United States Court of Appeals for the Fourth Circuit, Fourth Circuit precedent should control.” Petitioners cite People Helpers Fndn. v. City of Richmond, 12 F.3d 1321 (4th Cir. 1993) for the proposition that without proof of “actionable harm, compensatory damages are not recoverable and logically it follows that punitive damages are also barred.” Accordingly, the judgment awarding punitive damages was error.
Respondent says that People Helpers is non-§1983 case and is, therefore, distinguishable. Petitioner’s quotation from People Helpers simply recaps the general rule of law. The majority of cases addressing this issue in a §1983 context find that a punitive damages award can stand regardless of whether, or not, there is an underlying award of compensatory damages: “As a matter of federal law, a punitive damages award may endure even though unaccompanied by an award of compensatory damages.”
This case provides an opportunity for the Supreme Court to decide if §1983 cases will be treated differently for punitive damages purposes. Federal law appears to presume damages where the jury finds that a constitutional violation has, in fact, occurred. In light of the remedial purposes of §1983, the Supreme Court should adopt the same rule and codify it a new syllabus.