The Second Circuit Court of Appeals affirmed a $67,000 jury verdict in a civil rights action brought by a former Rikers Island prisoner. It also remanded for further proceedings on a malicious prosecution claim that had been improperly dismissed.
While at the Rikers Island jail complex serving a misdemeanor sentence, Axel Rentas was ordered on July 12, 2007 to move to a new bed. The events that occurred after that were hotly disputed, but it was undisputed that a fight between Rentas and several guards ensued.
Rentas alleged that after he was placed in handcuffs, Captain John Ruffin and other jailers “proceeded to punch, kick and pepper spray him,” then as he was carried away, “they purposely dropped him on his face.” Another beating occurred that included Deputy Wardens Walter Nin and Elison Perez as participants when he arrived at intake. There was no dispute that Rentas suffered a fractured eye socket, bruises, abrasions all over his body and bleeding in his lungs.
The incident prolonged Rentas’ release, which was scheduled less than three weeks later, because he was charged with multiple counts of felony assault and detained for three years before being acquitted at trial. Following his acquittal, Rentas sued the guards involved and the City of New York, asserting claims of excessive use of force, assault and battery, malicious prosecution, denial of his right to a fair trial, intentional infliction of emotional destress (IIED) and failure to intercede to protect him from the violation of his constitutional rights.
The district court dismissed the malicious prosecution claim, reasoning that “prosecutors exercised an independent decision to prosecute based on ... evidence of the officers’ injuries and the statements of other inmates who claimed that [Rentas] started the altercation.”
The case went to trial in October 2013 on the remaining claims, with the jury finding Ruffin individually liable for denying Rentas’ right to a fair trial, subjecting him to excessive force and failing to intercede, while all the defendants were found liable for IIED. The jurors awarded Rentas $67,000 in compensatory damages on the IIED claim but only nominal damages on the other claims. Both sides appealed.
On March 8, 2016, the Second Circuit held the malicious prosecution claim had been improperly dismissed. It was unclear to the Court of Appeals whether the statements the district court had relied upon, which were from other prisoners, constituted “independent, untainted information upon which a prosecution may rely to break the chain of causation.”
The appellate court’s doubts were reinforced by testimony from the Assistant District Attorney who brought the assault charges, who acknowledged that she had relied on the prisoners’ statements.
Otherwise, the jury verdict and damages award were affirmed. The Second Circuit also found that Ruffin’s motion for judgment as a matter of law had been properly denied by the district court. The case was remanded for further proceedings. See: Rentas v. Ruffin, 816 F.3d 214 (2d Cir. 2016).
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