Court of Appeals affirms $500,000 punitive damages award in inmate beating case

This case yielded a large jury verdict in favor of an inmate who claims he was beaten up by correction officers. After the jury awarded plaintiff $950,000 in punitive damages, the trial court reduced it to $500,000. The officers appealed, raising a host of issues, all of which the Court of Appeals rejects. The verdict stands and the inmate will recover $500,000.

The case is Magalios v. Peralta, a summary order issued on July 19. The jury also awarded $50,000 in pain and suffering, but that amount is not challenged on appeal. 

Once the jury reaches a verdict, the losing side usually files post-trial motions and then an appeal hoping to throw out the whole verdict or at least reduce the damages. That is why these cases sometimes go on for years after the jury goes home, unaware that the case is still active on the docket. There are many ways to challenge a verdict, including attacking the trial court's evidentiary rulings. That was the strategy here, though federal practitioners know that trial judges are afforded much deference in their evidentiary rulings.

The trial court in this case noted that "this was one of the strongest cases for excessive force I have seen in my years on the bench." The trial court also said that "some of Defendants' testimony was laughable." She also said that "'reprehensible' may not be a strong enough word to describe Defendants' conduct here. They have disgraced themselves and their office, and such conduct seems to be all to acceptable among certain employees of New York's prison system." The trial court further said the jury was "plainly disgusted by Defendants' conduct, and they would likely be equally disgusted if they learned that Defendants were to suffer no professional or financial repercussions from their actions and that the taxpayers of New York State were instead going to satisfy Plaintiff's judgment." And, she said, "I cannot think of a more effective tool for deterring future misconduct than a correction officer, who has been found to have engaged in wanton or malicious violation of constitutional rights, having is wages garnished or losing his savings or real property."

One evidentiary argument was that the trial court did not allow defendants to tell the jury that plaintiff had a prior felony conviction for promoting prison contraband. Defendants probably thought this evidence would turn the jury away from plaintiff's claims. But the district court held, and the Second Circuit agrees, that this evidence would only confuse the jury and suggest that Defendants actually knew about the prior felony and that this knowledge motivated their assault against plaintiff. Besides, the jury knew about plaintiff's other felony convictions, and cases hold that "once credibility is impeached by a prior felony conviction, the incremental probative force of a second conviction is minimal." Defendants also wanted the jury to know that plaintiff's witness, Hall, had a manslaughter conviction. But the trial court said, and the Court of Appeals agrees, that introducing this evidence at trial would be far more prejudicial than relevant.

We have other evidentiary rulings. Plaintiff's then-wife, Tibaldi, testified in deposition that plaintiff had called after after the officers had assaulted him. That testimony would support plaintiff's claim. But she was going to testify at trial that this deposition testimony was not true and that plaintiff was fabricating his allegations. This revised testimony would help the officers at trial, but the trial court warned Tribaldi that such testimony might lead to a perjury charge against her. After that happened, Tribaldi decided not to testify because "she is scared for her safety." The trial court's legal advice to Tribaldi did not deny defendants a fair trial because the warning discouraged her from testifying. But the Court of Appeals (Chin, Carney and Lee) holds that the trial court did not abuse its discretion in saying this to Tribaldi, and besides, Tribaldi did not change her mind about testifying over fear of a possible perjury charge but because she was afraid for her safety. That's two different things, the Court of Appeals notes. 

Plaintiff raised an issue on appeal on his own: that the $950,000 punitive damages award should not have been reduced to $500,000. But the Court of Appeals holds that the trial court did nothing wrong because it (1) found the force used against plaintiff was reprehensible even as it held (2) the damages were too high based on similar cases that awarded less money than the jury awarded in this case.