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The State of Connecticut has in place certain laws that allow the state to charge inmates for the cost of incarceration and even the use of its public defenders. This case asks whether the state could recoup those costs from a Connecticut inmate's successful lawsuit against a correction officer for excessive force. The Court of Appeals rules in favor of the inmate.
The case is Williams v. Marinelli, issued on February 4. Williams won his lawsuit against Marinelli, winning $250,000 for physical injuries sustained when prison guards knowingly placed him in a cell with a gang member who beat him senseless. Williams was also awarded $50,000 in punitive damages. After Williams won the trial, the state sent approximately $142,000 of that amount to the state coffers to pay for his incarceration, sending that same amount into Williams' personal account. The state also took $48,000 from the judgment to reimburse the state for Williams' use of the public defender in his criminal case. In response, Williams filed a motion to undo these maneuvers, claiming that these clawbacks were inconsistent with Section 1983, the federal civil rights law that was intended to deter civil rights violations. The state court agreed with Williams, noting that the state law guiding these maneuvers conflicted with the purposes of Section 1983 and that the state's decision to indemnify the defendant meant that state employees had a diminished incentive to respect civil rights.
The Second Circuit (Leval, Carney and Stanceu [D.J.]) affirms, ruling in Williams' favor. The state laws at issue in this case are preempted by Section 1983 under the "conflict preemption" principle that a local law conflicts with Section 1983 when it "stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress." The Court of Appeals agrees that the state cannot take this money from the plaintiff's civil rights recovery because that would conflicts with the values promoted by Section 1983. The Court reasons:
Upon consideration of all the facts of this unusual case, we conclude that Connecticut's actions conflict irreconcilably with § 1983’s purpose of deterring constitutional violations. The deterrent effect of Williams's § 1983 award is eviscerated if both the constitutional tortfeasor and his employer, the State, are relieved of the bulk of the financial consequences of the violation. We conclude that the State's actions here conflict sufficiently sharply with § 1983’s goals, particularly the goal of deterring state officers from abusing prisoners in their charge in violation of their constitutional rights, to justify the district court's conclusion that the State's attempt to discharge Marinelli's judgment obligations while recouping more than half the judgment through its cost-recovery statutes is preempted by § 1983, and the judgment against Marinelli remains outstanding.
The Court is careful to note this is a fact-specific holding that does not otherwise prevent the normal operation of these clawback statutes. The Court rules in plaintiff's favor because (1) the jury found that defendant acted maliciously and recklessly and awarded punitive damages against him; (2) plaintiff suffered serious injuries; (3) the state agreed to indemnify the defendant for these damages, which means that allowing the state to recoup its incarceration costs against defendant would "substantially undermine the deterrent effect that the risk of personal liability otherwise would have on a state official"; (4) such recoupment would deprive plaintiff of at least 60% of his judgment; (5) plaintiff has a lengthy sentence, which means the cost of his incarceration is high, thus "inform[ing] corrections officers from the day of his imprisonment that the risk of suit against them is diminished by the likelihood that any recovery achieved by the prisoner can be very substantially reduced by the State's cost recovery; and (6) the recoupment for incarceration and public defender debts "apply broadly to a significant portion of the inmate population (or, in the case of the cost of incarceration statutes, apparently all of that population), making it easier for officials to know ex ante that prisoners’ civil recoveries will likely be reduced by operation of the Connecticut cost-recovery statutes."
This is the second ruling from the Court of Appeals in 10 days that favors an inmate at Northern Correctional Facility in Connecticut. On January 27, the Court of Appeals reinstated a jury verdict in favor of an inmate who was awarded $750,000 in damages for the denial of exercise under the Eighth Amendment, a case that I argued. Read all about that case at this link.
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