Hall v. St. Helena Parish Sheriff's Department

Citations: 668 F. Supp. 535; 1987 U.S. Dist. LEXIS 8014Docket: Civ. A. 83-200-A

Court: District Court, M.D. Louisiana; July 28, 1987; Federal District Court

SummaryOriginalCytator Case TreatmentAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

Cleo Hall and Fabian Scott, two young men from Greensburg, Louisiana, were returning home from a job-hunting trip in Texas on February 20, 1982, when they drove Hall's Ford into a ditch after consuming alcohol. They were not injured, and the vehicle was operable. A passing motorist reported the incident to the St. Helena Parish sheriff's office, prompting Deputy Alton D. Clark to arrive. He detected alcohol on both men and intended to obtain a blood alcohol reading from Hall, although neither was informed of any charges or why they were being detained. Hall received a citation for reckless operation of a vehicle.

Deputy David Lea later arrived and, upon ascertaining Hall was the driver, questioned him about allegedly running a "white lady" off the road. This escalated into an altercation where Lea threatened Hall and physically assaulted him, leading Hall to retaliate. Lea then drew his firearm and assaulted Hall with it. The deputies' interactions were marked by racial undertones, as both were aware of the racial dynamics involved in the situation.

Lea assaulted Hall by striking him multiple times with a pistol barrel, resulting in Hall collapsing on the highway. After this, Lea kicked Hall, who lost consciousness. Despite the arrival of an ambulance, Lea demanded Hall get up unaided. Hall was treated at St. Helena Parish Hospital for five lacerations to the left side of his head, requiring seven stitches. He also experienced pain in his jaw and ribs. Medical evaluations confirmed no fractures or brain damage, and Dr. J.W. Varnado testified that Hall sustained no permanent injury, although Hall reported ongoing headaches and a jaw "knot." Blood tests indicated Hall had a blood alcohol level of .15 and .14, with no explanation provided for these results. Hall faced multiple charges, including simple battery, reckless driving, DWI, resisting an officer, and public intimidation, eventually being convicted of public intimidation and sentenced to one year in jail along with fines. 

Defendants in the case include deputies Clark and Lea, and Sheriff Duncan Bridges. Attempts to depose Sheriff Bridges were unsuccessful due to health issues, but it was stipulated that he would admit the following: the Sheriff's Department provided no training on the use of force to Officer David Lee, who had no post-recruit training; Lee was not disciplined after being found guilty of violating civil rights in a separate case; there were complaints from community members regarding Hall's arrest that went uninvestigated; and there was no policy established for handling resistant arrestees. There is no evidence that Sheriff Bridges was aware of or participated in the assault on Hall.

Deputies Clark and Lea acted under state law during Hall's beating on February 20, 1982. The court has jurisdiction under 28 U.S.C. 1343(a)(3) for this 42 U.S.C. 1983 action, concerning the deprivation of constitutional rights. Plaintiff claims Clark's arrest was illegal due to a lack of probable cause; however, an acquittal does not negate probable cause if the officer had reasonable cause to arrest for any related charge. Evidence including an accident report, the presence of alcohol, and reckless driving justified Hall's initial arrest, establishing probable cause.

Despite the lawful nature of the arrest, Hall's protection under the Fourteenth Amendment against post-arrest brutality is emphasized. Lea's malicious beating of Hall, who was unarmed and posed no threat, constituted a violation of Hall's rights. Consequently, Lea is liable under 42 U.S.C. 1983 and Louisiana tort law. 

Regarding Clark, although he falsely arrested a passenger, Scott, who is not part of this case, Hall's arrest was lawful. Clark's inconsistent testimony and lack of evidence connecting him to the beating prevent a finding of liability under 42 U.S.C. 1983 or Louisiana state law negligence. Thus, no recovery against Clark will occur.

The sheriff is not liable under 42 U.S.C. § 1983 for Deputy Lea's actions based on a failure to train or investigate, as liability under § 1983 requires personal involvement or approval of a custom or policy, which is not present here. The incident did not involve excessive force during an arrest since the suspect was already subdued and seated. The sheriff’s lack of direct involvement or an established policy related to the incident absolves him of liability under federal law. However, under Louisiana law, he can be held liable in his official capacity for Deputy Lea’s torts committed within the scope of employment. 

The plaintiff, Hall, suffered no permanent injury but incurred $100 in special damages for medical expenses and is awarded $5,000 in compensatory damages for pain and suffering, totaling $5,100 against Deputy Lea and Sheriff Bridges in his official capacity. Punitive damages may be awarded under § 1983 to deter constitutional violations, emphasizing the distinction between punitive and compensatory damages.

Lea's intentional and malicious assault on an unarmed arrestee necessitates punishment and serves as a warning to deter similar misconduct among law enforcement. This case is not isolated; the court previously found Lea liable for violating a citizen's constitutional rights in Rena Day v. David Lea, Civil Action 81-827. The court awards punitive damages of $100,000 against Lea, deemed sufficient to punish him and deter others. 

Additionally, the plaintiff is entitled to attorney's fees under 42 U.S.C. § 1988. While counsel submitted a total of 115.75 hours at an hourly rate of $85, the court finds the reasonable rate to be $75 per hour and limits the recoverable hours to 75, concluding that $5,625 is an appropriate fee. Excessive time spent on phone conferences with co-counsel was noted as a factor in this determination.

Counsel also requested damages for "false charges" by Lea and the resulting escalation of a minor incident into significant personal and legal turmoil for the plaintiff. However, the court notes that the plaintiff did not challenge his state court conviction in his pleadings or pretrial order, nor was there evidence of pursued remedies. The court concludes that the case is confined to the personal injuries inflicted post-arrest by Deputy Lea, and judgment will reflect this limitation.