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DC Prisoner Wins $175,000 in Conditions Case
by David C. Fathi
On January 25, 2001, a federal jury in Washington, D.C. awarded nearly $175,000 to D.C. prisoner Lawrence Caldwell in his challenge to conditions at the District of Columbia's Maximum Security Facility (MSF) in Lorton, Virginia. The award included $25,000 each in punitive damages against the Warden and Deputy Warden of MSF, where Caldwell was housed until the facility's recent closure.
Caldwell filed suit pro se in 1997, challenging the conditions of his confinement in MSF's notorious Cellblock 3. After the suit survived a motion to dismiss (See: Caldwell v. Hammonds , 53 F.Supp.2d 1 (D.D.C. 1999)) [ PLN , March 2001], the court appointed Elizabeth Alexander, Director of the ACLU National Prison Project, to represent Caldwell.
In his amended complaint, Caldwell alleged that he was held on the mental health tier of Cellblock 3 for 3 1/2 months, although the prison psychiatrist found that he was not mentally ill. Conditions on the mental health tier included nearly constant screaming and fecesthrowing by severely mentally ill prisoners, as well as poor ventilation, extreme heat, and frequent fires and flooding. Caldwell was then held in other segregation units (Cellblocks 2 and 4) for over two years, and then returned to Cellblock 3 for another year. He was released to general population only after U. S. District Judge Gladys Kessler ruled that prison officials had violated the District of Columbia's Lorton Act by keeping him in segregation after the prison's Housing Board repeatedly voted to release him to population.
Caldwell also charged that prison officials had failed to treat his skin cancer and glaucoma. After a dermatologist found that Caldwell needed surgery and ordered that he return within a month, prison officials waited nearly a year before taking him back to the dermatologist. As a result, Caldwell required a more invasive and painful form of surgery to remove a cancerous growth from his face. Security staff also ignored medical orders that Caldwell be provided a broadbrimmed hat and longsleeved shirts to protect his skin from further sun damage.
With the exception of the claim that conditions in Cellblocks 2 and 4 violated the Eighth Amendment, the jury found for Caldwell on all of his claims: that his transfer to a mental health unit without a hearing denied him due process under Vitek v. Jones , 445 U.S. 480 (1980); that conditions in Cellblock 3, and defendants' failure to treat his medical conditions, violated the Eighth Amendment; and that Caldwell's case managers violated the Lorton Act by failing to schedule hearings that could have resulted in his release from segregation.
The jury awarded $1,501 against Robert Wiley, the officer who placed Caldwell on the mental health tier; $116,576 against the District of Columbia, MSF Warden Adrienne Poteat and Deputy Warden Belinda Watson Barney; $5,200 against the District of Columbia and Poteat; $1.00 each against Case Managers JoAnn Williams and Rex Ihezue; $900 against the District of Columbia, Poteat, Watson Barney, and Robert Fulton, the officer who overruled Caldwell's medical orders; and $25,000 each in punitive damages against Poteat and Watson Barney. g
[David C. Fathi, a staff attorney at the ACLU National Prison Project in Washington, D.C., is co-counsel for Lawrence Caldwell. ]
On January 25, 2001, a federal jury in Washington, D.C. awarded nearly $175,000 to D.C. prisoner Lawrence Caldwell in his challenge to conditions at the District of Columbia's Maximum Security Facility (MSF) in Lorton, Virginia. The award included $25,000 each in punitive damages against the Warden and Deputy Warden of MSF, where Caldwell was housed until the facility's recent closure.
Caldwell filed suit pro se in 1997, challenging the conditions of his confinement in MSF's notorious Cellblock 3. After the suit survived a motion to dismiss (See: Caldwell v. Hammonds , 53 F.Supp.2d 1 (D.D.C. 1999)) [ PLN , March 2001], the court appointed Elizabeth Alexander, Director of the ACLU National Prison Project, to represent Caldwell.
In his amended complaint, Caldwell alleged that he was held on the mental health tier of Cellblock 3 for 3 1/2 months, although the prison psychiatrist found that he was not mentally ill. Conditions on the mental health tier included nearly constant screaming and fecesthrowing by severely mentally ill prisoners, as well as poor ventilation, extreme heat, and frequent fires and flooding. Caldwell was then held in other segregation units (Cellblocks 2 and 4) for over two years, and then returned to Cellblock 3 for another year. He was released to general population only after U. S. District Judge Gladys Kessler ruled that prison officials had violated the District of Columbia's Lorton Act by keeping him in segregation after the prison's Housing Board repeatedly voted to release him to population.
Caldwell also charged that prison officials had failed to treat his skin cancer and glaucoma. After a dermatologist found that Caldwell needed surgery and ordered that he return within a month, prison officials waited nearly a year before taking him back to the dermatologist. As a result, Caldwell required a more invasive and painful form of surgery to remove a cancerous growth from his face. Security staff also ignored medical orders that Caldwell be provided a broadbrimmed hat and longsleeved shirts to protect his skin from further sun damage.
With the exception of the claim that conditions in Cellblocks 2 and 4 violated the Eighth Amendment, the jury found for Caldwell on all of his claims: that his transfer to a mental health unit without a hearing denied him due process under Vitek v. Jones , 445 U.S. 480 (1980); that conditions in Cellblock 3, and defendants' failure to treat his medical conditions, violated the Eighth Amendment; and that Caldwell's case managers violated the Lorton Act by failing to schedule hearings that could have resulted in his release from segregation.
The jury awarded $1,501 against Robert Wiley, the officer who placed Caldwell on the mental health tier; $116,576 against the District of Columbia, MSF Warden Adrienne Poteat and Deputy Warden Belinda Watson Barney; $5,200 against the District of Columbia and Poteat; $1.00 each against Case Managers JoAnn Williams and Rex Ihezue; $900 against the District of Columbia, Poteat, Watson Barney, and Robert Fulton, the officer who overruled Caldwell's medical orders; and $25,000 each in punitive damages against Poteat and Watson Barney. g
[David C. Fathi, a staff attorney at the ACLU National Prison Project in Washington, D.C., is co-counsel for Lawrence Caldwell. ]
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Related legal case
Caldwell v. Hammonds
| Year | 2001 |
|---|---|
| Cite | USDC D DC Case No. CIV-A 97-2405 (9k) |
| Level | District Court |
| Conclusion | Jury Verdict |
| Attorney Fees | 0 |
| Damages | 175000 |
| Injunction Status | N/A |