Punitive Damages

Affirming punitive award of $850,000 where compensatory award was $400,000; officer opened cell door directly into then-naked detainee and employed head slams, leg sweep, and hip toss against detainee in separate incidents.

Sustaining awards of punitive damages totaling $355,000 where officers beat plaintiff unconscious, causing severe injuries, then covered up their misconduct by falsely accusing plaintiff of assault leading to his arrest and incarceration, in consideration of officers’ violence, trickery and deceit, and intentional malice, and compensatory damages were $90,000.

Affirming denial of punitive damages where plaintiff received nominal damages for arrest for yelling “fuck you” to officer who was performing traffic stop on vehicle with children in car, where trooper believed plaintiff had committed disorderly conduct and was concerned about children’s reaction to it.

Where compensatory damages were $47,300 and jury awarded punitive damages of $1,000,000, district court’s remittitur to $236,500 was reversed; Appeals Court awarded $425,700 based on a 9-1 ratio with compensatory damages, due to reprehensibility of defendant’s conduct—dropping unconscious plaintiff face-first onto concrete.

Punitive award of $200,000 was a violation of due process where plaintiff received only $1.00 in compensatory damages from jury, where officer choked, punched, and used knee strike on plaintiff after he surrendered following attempt to flee; court reduces punitive award to $50,000; court affirms award of fees to plaintiff’s counsel in amount of $143,787.97.