The inmate in this case alleges that a correction officer beat the hell out of him in the prison, causing serious physical injuries. The jury agreed with the inmate awarding him $190,000 in damage for pain and suffering. The federal court upheld the jury's findings on liability and damages.
The case is Tranchina v. McGrath, 2021 WL 1599189 (N.D.N.Y. April 23, 2021). This case went to trial in the Northern District of New York. That venue is not considered a receptive place for plaintiffs' verdicts, but plaintiffs do win from time to time. What makes this case unusual is the plaintiff was an inmate. People normally do not believe prisoners who claim they were beaten up by correction officers. Not this case. The inmate won.
Plaintiff says Officer McGrath gave him a pat frisk when plaintiff was on his way to his regularly-scheduled classes in the prison. McGrath accused him of having a weapon, which plaintiff denied. Plaintiff says that McGrath actually planted a weapon on him. The pat frisk caused plaintiff to hit the floor and, while he was on the ground, McGrath hit him repeatedly on the side of the head and ribs until he almost lost consciousness. Plaintiff says a second officer, Barnaby, kicked him in the face and groin. McGrath ultimately reported plaintiff for carrying a shank, but an internal investigation vindicated plaintiff. No shank! The jury found against McGrath, exonerated Barnaby, and awarded plaintiff $190,000 in damages.
Post trial, the state moves for judgment as a matter of law and, in the alternative, to reduce the damages award. But Judge D'Agostino says the jury had an evidentiary basis to find for plaintiff. Of course, the jury was not required to find in his favor, but once the jury enters its verdict, we assume that it credited all evidence favorable to plaintiff and rejected any evidence favorable to McGrath. That's why most post-verdict motions fail.
The medical records show that plaintiff sustained serious injuries to the right side of his head. While McGrath argues that the jury only speculated that he caused these injuries in light of plaintiff's testimony that other officers also beat him up that day, Judge D'Agostino agrees with plaintiff that this verdict was not grounded in speculation, as the jury was able to distinguish between the injuries caused by McGrath and those caused by other officers. That's what juries are for. While McGrath says that some of plaintiff's testimony supports McGrath's argument that McGrath was not responsible for the injuries, "the jury is free to believe as little or as much of a witness' testimony as they deem appropriate," even if that witness is the plaintiff. The Court cites Zellner v. Summerlin, 494 U.S. 344 (2d Cir. 2007), for that proposition.
What about damages? Judge D'Agostino surveys damages awards in other cases and finds the $190,000 in this case falls within the reasonable range. If you want a good summary of such cases, take a look at this ruling. Cases like this range from $25,000 to $200,000 depending on the nature of the injuries.
The jury also awarded $50,000 in punitives. That amount is also upheld, as the evidence actually shows McGrath beat up the plaintiff because he had been flirting with McGrath's girlfriend at the prison. The evidence also suggests that McGrath planted a weapon on plaintiff in order to get him in trouble. Of course, there is no legitimate justification for such actions. Hence, the punitive damages.
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