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Blanche K. Scott v. Jerry L. Horton, Kershaw County Sheriff Harold Brown Joel Gainey James Truesdale, Jailer
Citations: 60 F.3d 824; 1995 U.S. App. LEXIS 26149; 1995 WL 404848Docket: 94-7266
Court: Court of Appeals for the Fourth Circuit; July 10, 1995; Federal Appellate Court
Blanche K. Scott, the plaintiff-appellant, appealed a jury verdict that awarded her $1,000 in actual damages but denied her request for punitive damages in her 42 U.S.C. § 1983 complaint for false arrest, false imprisonment, and violation of federal constitutional rights. The Fourth Circuit reviewed the record and found no reversible error. Key points from the appeal include: 1. **Dissatisfaction with Attorney**: Scott's claims largely stemmed from her dissatisfaction with her attorney's performance. The court noted that there is no right to counsel in civil cases, making these claims non-cognizable on appeal. 2. **Evidentiary Issues**: Scott's contention that the defendants were permitted to introduce more than two exhibits was deemed meritless, as she did not demonstrate any prejudice resulting from this ruling. 3. **Punitive Damages**: The court found that the denial of punitive damages did not shock the conscience and did not constitute a manifest abuse of discretion. The defendants' conduct was not deemed sufficiently egregious to warrant punitive damages. 4. **Affirmation of the Lower Court's Judgment**: The court affirmed the judgment based on the jury's verdict and noted that oral argument was unnecessary due to the sufficiency of the materials presented. 5. **Attorney's Fees Challenge**: Scott also contested the attorney's fees awarded, but her challenge was not properly before the court as she did not separately appeal the district court's post-judgment order regarding these fees. The judgment of the lower court was upheld in its entirety.