What's Past Is Prologue: Why the Prison Litigation Reform Act Does Not-and Should Not-Classify Punitive Damages As Prospective Relief

Summary

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The Prison Litigation Reform Act of 1995 (PLRA) arose from Congress's intent to curb frivolous and institutionally invasive prisoner civil rights litigation. In furtherance of its goals, the PLRA limits the prospective relief prisoners can receive to such relief that is narrowly tailored to the federal rights violation at issue and the least intrusive means necessary to correct the violation, otherwise known as the need-narrowness-intrusiveness standard. Under the PLRA, prospective relief includes all relief other than compensatory monetary damages. However, while the courts have frequently applied and interpreted the PLRA over the past decade, only one circuit has addressed whether prospective relief as defined in the PLRA includes punitive damages. In Johnson v. Breeden, the Eleventh Circuit held that the term "prospective relief" includes punitive damages and that as a result, the PLRA requires that punitive damages conform to the need-narrowness-intrusiveness standard. This Comment argues that based on the inherent differences between punitive damages and prospective relief, the text of the PLRA, and the legislative intent behind the statute, prospective relief as defined by the PLRA does not, and should not, encompass punitive damages awarded to prisoners for violations of federal law.

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What's Past Is Prologue: Why the Prison Litigation Reform Act Does Not-and Should Not-Classify Punitive Damages As Prospective Relief

INTRODUCTION

One day after work detail, a prisoner held in a United States correctional facility returns to his cell.2 He passes a prison guard who questions him about his possession of food items from the prison store. Without warning, the guard chokes him, punches him in the face, and throws him to the ground. The guard then kicks him, stomps on him, and beats him with a baton until the prisoner loses consciousness. The prisoner wakes up in the infirmary with multiple bruises, contusions, and lacerations. The prison investigates the incident and, as a result, fires the guard.

The prisoner files a civil action against the guard, alleging a violation of his Eighth Amendment right to be free from cruel and unusual punishment while imprisoned.3 The jury finds in the prisoner's favor and awards him $25,000 in compensatory damages plus $45,000 in punitive damages. The trial court upholds the punitive damages award, finding it not grossly excessive or arbitrary given the actual damages the prisoner suffered and the particularly egregious nature of the guard's conduct - the general standard imposed upon punitive damages.4

On appeal, the circuit court holds that under the Prison Litigation Reform Act of 1 9955 (PLRA), punitive damages constitute "prospective relief and as such must comply with the statute's restrictions on prospective relief. Specifically, such relief must be narrowly tailored to the federal rights violation at issue and be the least intrusive means necessary to correct the violation,6 also known as the need-narrownessintrusiveness standard.7 Based on this standard, the circuit court overturns the punitive damages award, holding that by firing the guard, the prison fully corrected the federal rights violation and that awarding punitive damages would therefore violate the need-narrownessintrusiveness standard. Thus, despite having sustained serious injury as a result of an egregious and intentional violation of his constitutional rights, the prisoner receives no punitive damages.

The Eleventh Circuit made such a scenario more likely when it decided Johnson v. Breeden.& There, the...

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