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Good Faith Defense Analyzed Under Objective and Subjective Factors; $210,000 Jail Conditions Verdict
Good Faith Defense Analyzed Under Objective and Subjective Factors; $210,000 Jail Conditions Verdict Upheld
The Fourth Circuit Court of Appeals held a district court properly applied a subjective and objective test to determine a defendant's good faith defense in a civil rights action. This suit was filed by prisoners at Virginia's Prince William County Jail, alleging they were subjected to overcrowding and other conditions that amounted to cruel and unusual punishment. The matter proceeded to a jury trial, which resulted in a $210,000 damage award for the prisoners. The County appealed, arguing the Court failed to evaluate the good faith defense under a strictly objective standard, and the evidence was insufficient to support the jury award.
The County argued that Harlow v. Fitzgerald, 457 U.S. 800, 102 S. Ct. 2727, 73 L. Ed. 2d 396 (1982) abolished the subjective element of the good faith defense. The Court disagreed, holding that while Harlow indicated the good faith defense turns primarily on objective factors, it did not hold than an exclusively objective standard was to be applied to claims that proceeded to trial. Therefore, the district court's instructions containing objective and subjective standards of good faith was proper. The Court held further that even the county conceded the jail had become a terrible facility" that exceeded permissible constitutional limitations." Accordingly, sufficient evidence existed for the jury's award and the district court's judgment was affirmed. See: McElveen v. County of Prince William, 725 F.2d 954 (4th Cir. 1984).
The Fourth Circuit Court of Appeals held a district court properly applied a subjective and objective test to determine a defendant's good faith defense in a civil rights action. This suit was filed by prisoners at Virginia's Prince William County Jail, alleging they were subjected to overcrowding and other conditions that amounted to cruel and unusual punishment. The matter proceeded to a jury trial, which resulted in a $210,000 damage award for the prisoners. The County appealed, arguing the Court failed to evaluate the good faith defense under a strictly objective standard, and the evidence was insufficient to support the jury award.
The County argued that Harlow v. Fitzgerald, 457 U.S. 800, 102 S. Ct. 2727, 73 L. Ed. 2d 396 (1982) abolished the subjective element of the good faith defense. The Court disagreed, holding that while Harlow indicated the good faith defense turns primarily on objective factors, it did not hold than an exclusively objective standard was to be applied to claims that proceeded to trial. Therefore, the district court's instructions containing objective and subjective standards of good faith was proper. The Court held further that even the county conceded the jail had become a terrible facility" that exceeded permissible constitutional limitations." Accordingly, sufficient evidence existed for the jury's award and the district court's judgment was affirmed. See: McElveen v. County of Prince William, 725 F.2d 954 (4th Cir. 1984).
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Related legal case
McElveen v. County of Prince William
| Year | 1984 |
|---|---|
| Cite | 725 F.2d 954 (4th Cir. 1984). |
| Level | Court of Appeals |
| Conclusion | Jury Verdict |
| Attorney Fees | 0 |
| Damages | 210000 |
| Injunction Status | N/A |
725 F.2d 954
United States Court of Appeals, Fourth Circuit.
Crayton E. McELVEEN, Jr.,; Geary Lee Jamison; on behalf of themselves and all
other inmates of Prince William County Jail, present and future, and Julia
Phillips; Larry Eugene Collins; Richard Murray; Jerry Michael Collins;
Jeffrey Proctor; Charles Cuniff; Kelly Roach; Milton Jackson; Westley S.
Blackburn; Bernard R. Richardson; William Edward Parker; James Edward
Parker; James Dodson; Charles Scarpone; Buddie Spicer; Matthew L. Wright;
Larry H. Shane; Joseph Deans, Jr.,; Eric Lee Backherms; Timothy Wayne
Orehowsky, Appellees,
v.
COUNTY OF PRINCE WILLIAM; Eileen Stout, Sup., Dumfries District; Donald
Kidwell, Sup., Woodbridge District; James J. McCoart, Sup., Neabsco District;
G. Richard Pfitzner, Sup., Coles District; Joseph D. Reading, Sup.,
Brentsville District; Kathleen K. Seefeldt, Sup., Occoquan District; Donald
L. White, Sup., Gainesville District; C.A. Rollins, Jr., Sheriff, Prince
William County, Appellants,
and
Terrell Don Hutto, Director, Virginia Department of Corrections; Sidney
Parker, Chairman, Virginia Board of Corrections; Joseph B. Benedetti, Member,
Virginia Board of Corrections; Donald W. Huffman, Member, Virginia Board of
Corrections; JoAnn P. Digennaro, Member, Virginia Board of Corrections;
Norvell K. Robinson, Member, Virginia Board of Corrections; William P. Kanto,
Member, Virginia Board of Corrections; Stephen D. Rosenthal, Member, Virginia
Board of Corrections; Arnold J. Smith, Jr., Member, Virginia Board of
Corrections; John W. Williams, III, Member, Virginia Board of Corrections;
individually and in their official capacities, Appellees.
No. 82-6679.
Argued Nov. 3, 1983.
Decided Jan. 26, 1984.
County appealed from orders of United States District Court for the Eastern District of Virginia, Richard L. Williams, J., denying its motions for directed verdict and judgment notwithstanding verdict on its cross claim in § 1983 prison conditions case. The Court of Appeals, K.K. Hall, Circuit Judge, held that: (1) standard employed by District Court in evaluating state's good-faith immunity defense was correct, and (2) substantial evidence supported award of compensatory damages to inmates.
Affirmed.
*955 John H. Foote, County Atty., Manassas, Va. (James E. Barnett, Asst. County Atty., Manassas, Va., James A. Welch, Wheaton, Md., on brief), for appellants.
Alan Katz, Asst. Atty. Gen., Richmond, Va. (Gerald L. Baliles, Atty. Gen. of Va., Eric K.G. Fiske, Asst. Atty. Gen., Richmond, Va., on brief) and Marilyn G. Rose, Dumfries, Va. (Ervan E. Kuhnke, Jr., Dumfries, Va., Victor M. Glasberg, Alexandria, Va., on brief), for appellees.
Before WIDENER, HALL and MURNAGHAN, Circuit Judges.
K.K. HALL, Circuit Judge:
Prince William County, the Sheriff of Prince William County, and the Prince William County Board of Supervisors (collectively referred to as the "County") appeal from orders denying the County's motions for a directed verdict and judgment notwithstanding the verdict on its cross-claim against the Chairman and the Director of the Virginia Board of Corrections, and members of the State Board of Corrections (collectively referred to as the "State") in an action filed by inmates of the Prince William County Jail pursuant to 42 U.S.C. § 1983. The County also appeals from a judgment entered on a jury award of compensatory damages in favor of the inmates. Finding no error, we affirm.
I.
This action was filed in November, 1981, by an inmate and an ex-inmate of the Prince William County Jail (the "Jail"). [FN1] Plaintiffs alleged that during their incarceration they were subjected to overcrowding and other conditions which amounted to cruel and unusual punishment. They requested declaratory and injunctive relief and damages. Named defendants included the County and the State. All defendants except Prince William County were sued in both their individual and official capacities. [FN2]
FN1. Subsequently, the court granted class certification to all persons incarcerated in the Jail from August 1, 1980, through January 22, 1982.
FN2. Before trial, the Sheriff of Prince William County was dismissed as a defendant in his individual capacity.
The County filed a cross-claim against the State, alleging that the State had an obligation to depopulate the Jail by transferring inmates to other local jails, or into *956 the state penal system. The County also asserted that the State's failure to depopulate the Jail rendered the State jointly liable with the County for any verdict based upon overcrowding. The State claimed "good faith" or qualified immunity from such liability.
A bifurcated jury trial was conducted on the issues of liability and damages. During the liability portion of the trial, plaintiffs presented evidence that they had been subjected to unconstitutional overcrowding, poor sanitation, understaffing, and lack of access to a law library. The County admitted that jail conditions were poor, but denied liability, and presented evidence that the State was aware of the overcrowded conditions. The State conceded that the Jail was overcrowded but nevertheless denied liability. The State presented evidence that the Board of Corrections had discussed the situation with its counsel and, upon his advice, requested the County Circuit Court to order the County to either depopulate the Jail or erect a new jail. Shortly thereafter, the Board was advised by the Chief Judge of the County Circuit Court that the planning process was underway for a new jail. The State emphasized that the Board's communication with the state court was the only action it could have taken to limit overcrowding in the Jail. The State also presented evidence that the Department of Corrections transferred some inmates out of the Jail and could not have transferred any more without overburdening other local facilities or the State penitentiary. At the close of the State's evidence the County moved for a directed verdict on its cross-claim. The district judge deferred ruling on this motion and, instead, took the cross-claim under advisement.
United States Court of Appeals, Fourth Circuit.
Crayton E. McELVEEN, Jr.,; Geary Lee Jamison; on behalf of themselves and all
other inmates of Prince William County Jail, present and future, and Julia
Phillips; Larry Eugene Collins; Richard Murray; Jerry Michael Collins;
Jeffrey Proctor; Charles Cuniff; Kelly Roach; Milton Jackson; Westley S.
Blackburn; Bernard R. Richardson; William Edward Parker; James Edward
Parker; James Dodson; Charles Scarpone; Buddie Spicer; Matthew L. Wright;
Larry H. Shane; Joseph Deans, Jr.,; Eric Lee Backherms; Timothy Wayne
Orehowsky, Appellees,
v.
COUNTY OF PRINCE WILLIAM; Eileen Stout, Sup., Dumfries District; Donald
Kidwell, Sup., Woodbridge District; James J. McCoart, Sup., Neabsco District;
G. Richard Pfitzner, Sup., Coles District; Joseph D. Reading, Sup.,
Brentsville District; Kathleen K. Seefeldt, Sup., Occoquan District; Donald
L. White, Sup., Gainesville District; C.A. Rollins, Jr., Sheriff, Prince
William County, Appellants,
and
Terrell Don Hutto, Director, Virginia Department of Corrections; Sidney
Parker, Chairman, Virginia Board of Corrections; Joseph B. Benedetti, Member,
Virginia Board of Corrections; Donald W. Huffman, Member, Virginia Board of
Corrections; JoAnn P. Digennaro, Member, Virginia Board of Corrections;
Norvell K. Robinson, Member, Virginia Board of Corrections; William P. Kanto,
Member, Virginia Board of Corrections; Stephen D. Rosenthal, Member, Virginia
Board of Corrections; Arnold J. Smith, Jr., Member, Virginia Board of
Corrections; John W. Williams, III, Member, Virginia Board of Corrections;
individually and in their official capacities, Appellees.
No. 82-6679.
Argued Nov. 3, 1983.
Decided Jan. 26, 1984.
County appealed from orders of United States District Court for the Eastern District of Virginia, Richard L. Williams, J., denying its motions for directed verdict and judgment notwithstanding verdict on its cross claim in § 1983 prison conditions case. The Court of Appeals, K.K. Hall, Circuit Judge, held that: (1) standard employed by District Court in evaluating state's good-faith immunity defense was correct, and (2) substantial evidence supported award of compensatory damages to inmates.
Affirmed.
*955 John H. Foote, County Atty., Manassas, Va. (James E. Barnett, Asst. County Atty., Manassas, Va., James A. Welch, Wheaton, Md., on brief), for appellants.
Alan Katz, Asst. Atty. Gen., Richmond, Va. (Gerald L. Baliles, Atty. Gen. of Va., Eric K.G. Fiske, Asst. Atty. Gen., Richmond, Va., on brief) and Marilyn G. Rose, Dumfries, Va. (Ervan E. Kuhnke, Jr., Dumfries, Va., Victor M. Glasberg, Alexandria, Va., on brief), for appellees.
Before WIDENER, HALL and MURNAGHAN, Circuit Judges.
K.K. HALL, Circuit Judge:
Prince William County, the Sheriff of Prince William County, and the Prince William County Board of Supervisors (collectively referred to as the "County") appeal from orders denying the County's motions for a directed verdict and judgment notwithstanding the verdict on its cross-claim against the Chairman and the Director of the Virginia Board of Corrections, and members of the State Board of Corrections (collectively referred to as the "State") in an action filed by inmates of the Prince William County Jail pursuant to 42 U.S.C. § 1983. The County also appeals from a judgment entered on a jury award of compensatory damages in favor of the inmates. Finding no error, we affirm.
I.
This action was filed in November, 1981, by an inmate and an ex-inmate of the Prince William County Jail (the "Jail"). [FN1] Plaintiffs alleged that during their incarceration they were subjected to overcrowding and other conditions which amounted to cruel and unusual punishment. They requested declaratory and injunctive relief and damages. Named defendants included the County and the State. All defendants except Prince William County were sued in both their individual and official capacities. [FN2]
FN1. Subsequently, the court granted class certification to all persons incarcerated in the Jail from August 1, 1980, through January 22, 1982.
FN2. Before trial, the Sheriff of Prince William County was dismissed as a defendant in his individual capacity.
The County filed a cross-claim against the State, alleging that the State had an obligation to depopulate the Jail by transferring inmates to other local jails, or into *956 the state penal system. The County also asserted that the State's failure to depopulate the Jail rendered the State jointly liable with the County for any verdict based upon overcrowding. The State claimed "good faith" or qualified immunity from such liability.
A bifurcated jury trial was conducted on the issues of liability and damages. During the liability portion of the trial, plaintiffs presented evidence that they had been subjected to unconstitutional overcrowding, poor sanitation, understaffing, and lack of access to a law library. The County admitted that jail conditions were poor, but denied liability, and presented evidence that the State was aware of the overcrowded conditions. The State conceded that the Jail was overcrowded but nevertheless denied liability. The State presented evidence that the Board of Corrections had discussed the situation with its counsel and, upon his advice, requested the County Circuit Court to order the County to either depopulate the Jail or erect a new jail. Shortly thereafter, the Board was advised by the Chief Judge of the County Circuit Court that the planning process was underway for a new jail. The State emphasized that the Board's communication with the state court was the only action it could have taken to limit overcrowding in the Jail. The State also presented evidence that the Department of Corrections transferred some inmates out of the Jail and could not have transferred any more without overburdening other local facilities or the State penitentiary. At the close of the State's evidence the County moved for a directed verdict on its cross-claim. The district judge deferred ruling on this motion and, instead, took the cross-claim under advisement.