Jury awards modest punitive damages against prison warden
In Thompson v. Caruso, the court system functioned precisely as it was designed, in one of those many cases that do not garner publicity or notoriety. Two prisoners had sued the Director of the Michigan Department of Corrections to object to her policy of opening their legal mail outside the prisoners' presence. A 2003 Sixth Circuit Court decision, Sallier v. Brooks, had outlawed this practice, requiring that the prisoner be present when legal mail is opened, if the prisoner requests.
The jury awarded the prisoners only one dollar in compensatory damages, but it awarded each of them $2500 in punitive damages for the Department's deliberate and repeated constitutional violation. The Director appealed, claiming that the prisoners had not demonstrated that she acted with evil motive or intent, or with reckless or callous indifference to the prisoners' federally-protected rights. The sitting Judge rejected the Director's appeal, holding that the jury decision was not unreasonable.
The Court also held that the punitive damage award did not need to be reduced or "remitted" because it was disproportionate to the compensatory damages awarded. The Court noted that given the repeated nature of the violation and the difficulty in placing a value on Constitutional and legal rights, the punitive damage award was well within reasonable bounds.