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California Appellate Court Overturns $177,000 Prisoner Beating Verdict
by John E. Dannenberg
The California Court of Appeal (4th District) has reversed a $177,000 jury verdict against Orange County and its Sheriff, Michael Carona, finding that no substantial evidence supported the verdict and that the award of punitive damages violated due process.
In a jury trial, Orange County jail prisoner Robert Carter had been awarded $77,000 in compensatory damages and $100,000 in punitive damages for injuries he suffered when he was allegedly mistreated at the jail. His attorneys were awarded their full demand of $455,000 in fees plus $18,000 in costs. In a curious result, the jury found all jail personnel defendants not guilty of violating Carter's rights, but found the County liable for its inadequate policies to prevent the alleged mistreatment.
Although the jury awarded punitive damages, it was not specified who should pay them; the judge ordered Sheriff Carona to be liable. [See: PLN, Feb.'04, p.23].
Carter, a 20-year drug addict who suffered from heart problems and diabetes, had, in a four week trial, alleged multiple acts of mistreatment attending his repeated need for medical care while at the Orange County Jail. The acts included "hog-tying" him, failure to provide timely medical care, disrespect by deputies and nurses, and beatings. His liability theory went to each named deputy as well as to the Sheriff and County on respondeat superior theories.
The appellate court, in essence, retried the case from the trial record and agreed with the jury that no individual had violated Carter's rights.
First, the Court concluded that the exoneration of all the County's deputies meant that the County could not be held liable for the deputies' alleged actions. Carter's qualified immunity theory fell flat as well because no deputy was found guilty. As to Carter's complaint of improper grievance procedures, the evidence showed that they were followed every time. Nor was there evidence to support Carter's claim of lack of proper policies to provide medical care. Additionally, the asserted absence of such a policy could not have caused Carter's repeated chest pains. And even though Carter claimed his being placed in medical isolation compounded his angina attacks, the record showed he had such attacks when not in isolation, too. Thus, there was no requisite causal link between "lack of policy" and injury.
The appeals court cleared Sheriff Carona because he could only be held liable for his own personal actions, but Carter never claimed Carona directly caused him any harm. Since Carona did not even appear at trial, it certainly was not proved that he had knowledge of yet ignored his deputies' malfeasance. And since there was no evidence of Carona's personal liability, there was no basis for punitive damages against him.
Accordingly, the appellate court reversed the judgment and the post-judgment orders for punitive damages and attorney fees, while awarding costs on appeal to appellants. The appeals court issued a subsequent superseding ruling, but with the same result, in order to "clarify certain statements set out in the original opinion and to make it clear we had properly considered all of the evidence and arguments." See: Carter v. County of Orange, California Court of Appeal, 4th District, Case No. G032419, June 29, 2005 (2005 WL 1528623) (unpublished); vacated and superseded on rehearing, Aug. 9, 2005 (2005 WL 1871119) (unpublished).
The California Court of Appeal (4th District) has reversed a $177,000 jury verdict against Orange County and its Sheriff, Michael Carona, finding that no substantial evidence supported the verdict and that the award of punitive damages violated due process.
In a jury trial, Orange County jail prisoner Robert Carter had been awarded $77,000 in compensatory damages and $100,000 in punitive damages for injuries he suffered when he was allegedly mistreated at the jail. His attorneys were awarded their full demand of $455,000 in fees plus $18,000 in costs. In a curious result, the jury found all jail personnel defendants not guilty of violating Carter's rights, but found the County liable for its inadequate policies to prevent the alleged mistreatment.
Although the jury awarded punitive damages, it was not specified who should pay them; the judge ordered Sheriff Carona to be liable. [See: PLN, Feb.'04, p.23].
Carter, a 20-year drug addict who suffered from heart problems and diabetes, had, in a four week trial, alleged multiple acts of mistreatment attending his repeated need for medical care while at the Orange County Jail. The acts included "hog-tying" him, failure to provide timely medical care, disrespect by deputies and nurses, and beatings. His liability theory went to each named deputy as well as to the Sheriff and County on respondeat superior theories.
The appellate court, in essence, retried the case from the trial record and agreed with the jury that no individual had violated Carter's rights.
First, the Court concluded that the exoneration of all the County's deputies meant that the County could not be held liable for the deputies' alleged actions. Carter's qualified immunity theory fell flat as well because no deputy was found guilty. As to Carter's complaint of improper grievance procedures, the evidence showed that they were followed every time. Nor was there evidence to support Carter's claim of lack of proper policies to provide medical care. Additionally, the asserted absence of such a policy could not have caused Carter's repeated chest pains. And even though Carter claimed his being placed in medical isolation compounded his angina attacks, the record showed he had such attacks when not in isolation, too. Thus, there was no requisite causal link between "lack of policy" and injury.
The appeals court cleared Sheriff Carona because he could only be held liable for his own personal actions, but Carter never claimed Carona directly caused him any harm. Since Carona did not even appear at trial, it certainly was not proved that he had knowledge of yet ignored his deputies' malfeasance. And since there was no evidence of Carona's personal liability, there was no basis for punitive damages against him.
Accordingly, the appellate court reversed the judgment and the post-judgment orders for punitive damages and attorney fees, while awarding costs on appeal to appellants. The appeals court issued a subsequent superseding ruling, but with the same result, in order to "clarify certain statements set out in the original opinion and to make it clear we had properly considered all of the evidence and arguments." See: Carter v. County of Orange, California Court of Appeal, 4th District, Case No. G032419, June 29, 2005 (2005 WL 1528623) (unpublished); vacated and superseded on rehearing, Aug. 9, 2005 (2005 WL 1871119) (unpublished).
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Related legal case
Carter v. County of Orange
| Year | 2005 |
|---|---|
| Cite | CA Crt. of App., 4th District, # G032419 (2005) |
| Level | State Court of Appeals |
| Injunction Status | N/A |