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Colemann v. Vinson

United States District Court, S.D. Illinois

September 24, 2019

LT. VINSON, et al., Defendants.



         Plaintiff Dwaine Coleman filed this lawsuit pursuant to 42 U.S.C. § 1983 alleging his constitutional rights were violated while he was in the custody of the Illinois Department of Corrections (“IDOC”), incarcerated at Vienna Correctional Center (“Menard”). Plaintiff proceeded to trial on a claim of excessive force against Defendants James Vinson and Jared Blessing, and a claim of retaliation against David Mitchell. On October 3, 2018, the jury rendered its verdict in favor of Dwaine Coleman and against James Vinson on his claim of excessive force. The jury also rendered its verdict in favor of Defendants Blessing and Mitchell. The jury awarded Plaintiff $1.00 in compensatory damages and assessed punitive damages against Defendant Vinson in the amount of $35, 000.

         Now before the Court is Defendant Vinson’s Motion for Reduction or Remittitur (Doc. 85), Plaintiff’s Motion for Award of Attorneys’ Fees and Costs (Doc. 86), and Plaintiff’s Bill of Costs (Doc. 88). The Court sets forth its rulings as follows.

         1. Motion for Reduction or Remittitur (Doc. 85)

         Defendant asks that the Court reduce or remit Plaintiff’s award of punitive damages. Defendant brings his motion pursuant to Federal Rule of Civil Procedure 59(e).

         In considering whether a punitive damages award exceeds constitutional limits, courts are directed to consider: (1) the reprehensibility of the action in question; (2) the ratio between the compensatory and punitive damages; and (3) the difference between the damages award and the civil penalties authorized or imposed in comparable cases. BMW of North America, Inc. v. Gore, 517 U.S. 559, 575 (1996).

         “Perhaps the most important indicium of the reasonableness of a punitive damages award is the degree of reprehensibility of the defendant’s conduct.” Id. The Supreme Court has identified five factors for courts to consider in assessing the degree of reprehensibility of a defendant’s conduct: whether (1) the harm caused was physical as opposed to economic; (2) the tortious conduct evinced an indifference to or a reckless disregard of the health or safety of others; (3) the target of the conduct had financial vulnerability; (4) the conduct involved repeated actions or was an isolated incident; and (5) the harm was the result of intentional malice, trickery, or deceit, or mere accident. State Farm Mut. Auto Ins. Co. v. Campbell, 538 U.S. 408, 419 (2003).

         It is apparent that these factors weigh in favor of Plaintiff. First, the harm incurred was clearly physical and inflicted with indifference or a reckless disregard to Plaintiff’s health and safety. Further, according to Plaintiff’s trial testimony, Vinson’s conduct was inflicted with intentional malice as he slammed Plaintiff’s head against a doorjamb, cut into Plaintiff’s wrists with handcuffs, and grabbed and clenched his jaw without provocation (Doc. 83 at 19-21). While the incident at issue may have been isolated, Vinson took aggressive action toward Plaintiff three times.

         The next consideration is the relationship between the compensatory and punitive damages awarded. In Campbell, the Supreme Court declined to impose a bright-line ratio which a punitive damages award cannot exceed; however, the Court indicated that “few awards exceeding a single-digit ratio between punitive and compensatory damages … will satisfy due process.” State Farm Mut. Auto Ins., 538 U.S. at 425. In any event, the Seventh Circuit has found that “capping the ratio of compensatory and punitive damages makes sense only when the compensatory damages are large.” Lust v. Sealy, Inc., 383 F.3d 580, 591 (7th Cir. 2004). Indeed, in Cooper v. Casey, the Seventh Circuit recognized that “[t]he smaller the compensatory damages, the higher the ratio of punitive to compensatory damages has to be in order to fulfill the objectives of awarding punitive damages.” 97 F.3d 914, 919-20 (upholding a punitive damages award of $60, 000 per plaintiff where each plaintiff was awarded $5, 000 in compensatory damages). In Cooper, the Court explained:

The compensatory damages were low here in part because of the inherent difficulties of fixing a dollar equivalent for subjective injuries, such as fright and pain. An award of punitive damages proportioned to the low compensatory damages that were awarded would have a very meager deterrent effect, would fail to signal to the prison authorities that savage treatment of prisoners will not be tolerated, and would not be commensurate with the moral gravity of the defendant’s actions.

Id. at 920. The Court further noted that “the highest award of punitive damages against any one of the seven defendants was only $22, 500. The sky is not the limit, but $22, 500 is not the sky.” Id.

         In this instance, the jury awarded Plaintiff punitive damages in the amount of $35, 000. Although the jury only awarded Plaintiff nominal compensatory damages, the Court cannot find that the punitive damages awarded exceeds constitutional bounds. Indeed, as noted in Cooper, the injuries here were difficult to assign a dollar value. Moreover, to subject Plaintiff to a single ratio for punitive damages or to say that the $35, 000 award is too high a ratio in this case would not serve the purpose of punitive damages.

         Further, with regard to the comparability of the punitive damages award here with other cases, the Court finds it is not so far out of line with other cases wherein plaintiffs were awarded low or only nominal damages to require a reduction. See Wilson-El v. Mutayoba, Case No. 12-cv-203-NJR-DGW, 2015 WL 2201564 (S.D. Ill., May 8, 2015) (jury awarded $1.00 in compensatory damages and $10, 100 in punitive damages); Gevas v. Harrington, Case No. 10-cv-493-SCW, 2014 WL 4627689 (S.D. Ill., Sept. 16, 2014) (upholding $10, 000 in punitive damages on a nominal compensatory award); see also Hardy v. City of Milwaukee, 88 F.Supp.3d 852, (E.D. Wis., Feb. 27, 2015) (wherein district court reduced punitive damages award of $500, 000 to $54, 000 when jury awarded $6, 000 in compensatory damages); Kunz v. DeFelice, 538 F.3d 667, 679-80 (7th Cir. 2008) (upholding punitive damages award of $90, 000 with a compensatory damages award of $10, 000).

         For the above-mentioned reasons, the Court finds that the jury’s award of punitive damages in the amount of $35, 000 is within the reasonable range of awards that could have been assessed in this case and it is therefore within constitutional ...

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