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Federal Court Nullifies Seizure of Prisoner’s Civil Rights Award

On March 29, 2018, a Connecticut federal district court held state officials could not first indemnify a prison guard against whom a prisoner had won a jury award in a civil rights case, then seize the majority of the prisoner’s award for costs of incarceration and various other expenses and fees.

Connecticut prisoner Rashid Williams obtained a $300,000 jury award in a federal lawsuit in which he proved now-retired Connecticut Department of Correction (DOC) captain Dennis Marinelli intentionally and repeatedly had him placed in a cell with a violent gang member while handcuffed, knowing that would endanger him. As a result, Williams was severely beaten.

The jury awarded Williams $250,000 in compensatory damages plus $400,000 in punitive damages. The district court reduced the punitive damages award to $50,000.

State officials seized $15,140 of the judgment to reimburse Williams’ past child support obligations, took $142,430 for costs of incarceration and deposited the remaining $142,430 into his prison trust fund account. They then froze the account while they sought to recover another $42,842.42 for the cost of public defenders Williams had used during various criminal proceedings and for additional child support.

Williams filed a motion for aid of judgment, asking the federal court to declare that the state’s cost of incarceration statute, Con. Gen. Stat. § 18-85b, conflicts with 42 U.S.C. § 1983 and thus should be preempted as applied to the judgment in his case. He also sought to unfreeze his trust fund account and attached a copy of the state’s lawsuit to recover the public defender costs, which had been removed to federal court. That suit was later returned to state court.

The district court noted that Congress’ goal in creating § 1983 was to establish a judicial remedy against the violation of citizens’ federal civil rights by state officials. Its purpose was to provide compensation for past violations and deter future violations.

The court held that because punitive damages were awarded, the jury made an implied finding that Marinelli’s conduct was malicious or reckless. Due to that finding the state was not required to indemnify Marinelli, therefore it did so voluntarily. But in doing so, it defeated the deterrence purpose of § 1983 by sending a message to DOC employees that they would not be held personally liable for their malicious violations of prisoners’ civil rights.

The state then used its cost recovery statutes to deprive Williams of nearly 70% of his judgment against Marinelli, and sought to recover even more. That was a voluntary decision that greatly diminished the compensation purpose of § 1983.

The district court concluded that the state’s voluntary indemnification of Marinelli, coupled with its decision to claw-back the majority of the jury award, was in irreconcilable conflict with § 1983. Both decisions were discretionary and echoed the state law enforcement actions that had prompted Congress to enact § 1983.

The court noted that the Eleventh Amendment barred it from granting monetary relief against the state, so it could not simply order state officials to pay the judgment. But it could and did rule that the state’s indemnification had no effect on the judgment awarded against Marinelli, who was sued in his individual capacity, and that Williams may seek to recover that judgment from Marinelli, with interest but less his child support obligations, for a total of $287,433.92. See: Williams v. Murphy, U.S.D.C. (D. Conn.), Case No. 3:13-cv-01154-MPS; 2018 U.S. Dist. LEXIS 72833. 

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Related legal case

Williams v. Murphy