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$200,000 Injury Damages For Illinois Juvenile Prisoner Reduced To $40,000 For Total Versus Individual Award Confusion

15 year old Illinois Youth Center (IYC) prisoner Jeffrey Watts brought federal action against several IYC employees for cruel and unusual punishment in failure to protect after fellow prisoner Derrick Greaves allegedly attacked him. Watts suffered permanent leg and hip damage. Liability was awarded but confusion regarding the award for damages resulted in remand.

Watts alleged that Greave's attack came after he refused to join his gang and that several employees knew or should have known that the attack was imminent. A jury entered an award of $40,000 on each defendant's verdict form after granting Watts's liability claims. A judge entered judgment for $40,000 as to each defendant individually. The defendant's motion to clarify judgment resulted in a judges ruling that, due to the confusion, the award was a total of $40,000. Watts appealed and motioned to supplement the record with two juror's statements claiming that the jurors intended awards of $40,000 from each defendant.

On appeal, the Seventh Circuit affirmed the liability, remanded to determine if the jury intended the award as to each defendant or cumulatively, and denied Watts's motion to supplement the record. The court did, however, offer Watts a new trial to determine damages de novo, but warned that the commencement of a new damages trial would vacate the $40,000 already awarded. See: Watts v. Laurent, 774 F.2d 168 (7th Cir. 1985).

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Related legal case

Watts v. Laurent