The jury in this case found that the prison warden had denied an inmate his Eighth Amendment rights in knowingly allowing him to "exercise" in full body restraints for six months such that the inmate was not able to exercise at all. The trial judge had vacated the verdict, the Court of Appeals brings it back, determining the jury had a basis to find the warden was aware of the civil rights violation.
The case is Edwards v. Quiros, issued on January 27. I briefed and argued the appeal. The plaintiff is in a maximum security prison in Connecticut. Case law holds that inmates have the right under the Eighth Amendment (which prohibits cruel and unusual punishment) to exercise, including outdoor exercise. The prison does have exercise yards that allow high-security inmates to exercise outside without restraints, but that part of the prison was overcrowded, so plaintiff was in a different unit, whose exercise yards did not have the infrastructure (trap doors, etc.) that allowed the guards to safely remove the restraints so the inmate could go about his exercise routine, usually walking or jogging.
At trial, the warden said he did not know about plaintiff's restricted exercise for the duration of the six-month period in which plaintiff was standing around the exercise yard without movement. The warden said he only knew for eight days, which is not long enough to hold him liable for a constitutional violation. The warden said once he found out about plaintiff's exercise situation (which happened when plaintiff sent him a written grievance), he took action to permit plaintiff additional exercise. The jury, however, found the warden liable and awarded plaintiff $500,000 for pain and suffering and $250,000 in punitive damages.
The trial judge rejected the verdict post-trial, holding that the warden did not have sufficient personal knowledge of the rights violation to hold him liable. The Court of Appeals (Walker, Wesley and Katzmann) reinstates the verdict, holding that circumstantial evidence supports the jury's finding that the warden must have known all along what was going on. This evidence includes the fact that the warden knew that inmates in the overflow section of the jail were not able to fully exercise because that portion of the jail did not have the high-security infrastructure necessary to make that happen, and that the warden boasted at trial that he was the eyes and ears of the facility and paid close attention to what going on at the jail, in part through surveillance cameras. In sum, the Court of Appeals says,
Quiros presented himself to the jury as a hands-on warden who kept close tabs on the inmates on restrictive status under his purview. The jury was entitled to credit Quiros’s testimony in those respects and infer that in fact he did know that Edwards was in Unit Three, exercising in full restraints, until his transfer to AS Phase II status. We therefore respectfully find that the district court erred by drawing inferences against the verdict and by discrediting Quiros’s own testimony when it found that no evidence supported Quiros’s knowledge of Edwards’s recreation status prior to March 8, 2011, the date he received Edwards’s inmate request form.
In a follow-up post, I will talk about the merits of the case and why the Court of Appeals also found that plaintiff's rights were in fact violated. The oral argument is at this link. News coverage on the case is at this link.