Smith v. Wade

461 U.S. 30 (1983)

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Nature of the Case

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Facts

Smith is a guard at the Algoa Reformatory, a unit of the Missouri Department of Corrections for youthful first offenders. Wade was assigned to Algoa as an inmate in 1976. In the summer of 1976, Wade voluntarily checked into the protective custody unit. Because of disciplinary violations during his stay in protective custody, Wade was given a short term in punitive segregation and then transferred to administrative segregation. On the evening of Wade’s first day in administrative segregation, Wade was placed in a cell with another inmate. When Smith came on duty, he placed a third inmate in Wade’s cell. According to Wade, his cellmates harassed, beat and sexually assaulted him. Wade (P) sued under 42. U.S.C. 1983. P sued Smith (D), and four other guards and correctional officials alleging his Eighth Amendment rights have been violated. At trial, evidence showed that P had placed himself in protective custody because of prior incidents of violence against him by other inmates. The third prisoner that D had added to the cell had been placed in administrative segregation for fighting. D had made no effort to find out if another cell was available. In fact, there was another cell in the same dormitory with only one occupant. Further, only a few weeks earlier, another inmate had been beaten to death in the same dormitory during the same shift that D had been on duty. P asserted that D and the other Ds knew or should have known that an assault against P was likely under the circumstances. The district judge charged the jury that punitive damages would be available in order to punish a wrongdoer for some extraordinary misconduct and to serve as an example or warning to others not to engage in such conduct. The court then told the jury that if the conduct of one or more of the defendants is shown to be reckless or a callous disregard of, or indifference to, the rights or safety of others, then you may assess punitive or exemplary damages in addition to an award of actual damages. That amount of punitive damages must be such sum as to punish the defendant and to deter him and others from like conduct. D was found liable, and P was awarded $25,000 in compensatory damages and $5,000 in punitive damages. The Court of Appeals affirmed. D appealed the award of punitive damages.