Charles Lewis v. Freddie Smith, Mark Smith and Arnold Holt

Citations: 855 F.2d 736; 1988 U.S. App. LEXIS 12803; 1988 WL 90116Docket: 87-7575

Court: Court of Appeals for the Eleventh Circuit; September 19, 1988; Federal Appellate Court

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The Eleventh Circuit affirmed a $500 damage award to Charles Lewis, an Alabama prisoner, for procedural due process violations by prison officials Mark Smith, Freddie Smith, and Arnold Holt in a section 1983 action. Lewis claimed his rights were violated during a disciplinary hearing regarding contraband possession, where Mark Smith, Chairman of the Prison Disciplinary Committee, found him guilty without sufficient evidence or proper documentation, contrary to established legal standards and state regulations. Arnold Holt, the Work-Release Center Director, upheld this decision, while Freddie Smith, the Prison Commissioner, denied Lewis' appeal.

An evidentiary hearing revealed that the due process violations were evident to Holt and Smith during the appeal review, and Lewis experienced emotional distress, warranting the damage award. However, his request for injunctive relief to restore work-release status was denied due to a subsequent conviction for contraband possession.

Defendants' claim of qualified good faith immunity was rejected as they failed to present evidence supporting this defense during the evidentiary hearing or in subsequent memoranda. Additionally, since the defendants were found to have violated Lewis' clearly established constitutional rights, they could not claim this immunity. The district court adopted the magistrate's findings, leading to the defendants' appeal.

The claim against Freddie Smith and Holt was not founded on respondeat superior or negligence. Liability under Section 1983 requires more than mere negligence, as established in Monell v. New York City Dept. of Social Services and Daniels v. Williams. Supervisory liability can arise from a supervisor's direct involvement in the constitutional violation or a causal link between their actions and the violation, as noted in H.C. By Hewett v. Jarrard. The magistrate determined that Commissioner Smith and Director Holt had a responsibility under Regulation 403 to ensure compliance with Wolff during disciplinary actions, and they were aware of facial due process violations in the documents they reviewed. This conclusion was deemed not clearly erroneous. The prison superintendent, responsible for investigating appeals, failed to act on reports indicating potential constitutional violations, demonstrating reckless disregard for the plaintiff's rights and negating any good faith defense against liability under Section 1983.

Compensatory damages of $500 awarded to Lewis were found legally appropriate, as he experienced emotional distress due to violations related to his disciplinary process. The court ruled that such damages are justified in Section 1983 actions for procedural due process violations, referencing Carey v. Piphus. Smith and Holt's assertion that the district court attributed Lewis' injury solely to their violation of Regulation 403 was incorrect; the court determined their actions violated constitutional standards outlined in Wolff. Furthermore, the district court correctly upheld the decision to deny Lewis reinstatement of work-release status following his felony conviction while on work-release. The ruling was affirmed.