Beard v. Wexford Health Sources, Inc.

In section 1983 action filed by plaintiff-prisoner against defendant-provider of medical services to prison, in which jury awarded plaintiff $10,000 in compensatory and $500,000 in punitive damages arising out of defendant’s decision to deny doctors’ request for surgical evaluation of plaintiff’s ankle, where defendant instead treated said ankle conservatively, Dist. Ct. erred in reducing punitive award to $50,000 without giving plaintiff option to either accept said reduction or participate in new trial on issue of all damages. Although Dist. found that jury’s punitive damages award violated due process clause, said reduction to 5 times compensatory award was arbitrary, and defendant had never requested that Dist. Ct. reduce punitive damages award without giving plaintiff option of new trial on damages. As such, remand was required to allow plaintiff to make such election. Ct. further declined to rule as to whether punitive damage award in section 1983 action at five times compensatory award would violate either constitutional of statutory limitations.