Livingston v. Goord.

• Position: Compensatory damages - Brief Article

U.S. District Court

COMPENSATORY DAMAGES

STATE LIABILITY

Livingston v. Goord, 225 F.Supp.2d 321 (W.D.N.Y. 2002). A pro se state prisoner brought a [section] 1983 action against corrections officials and employees. The prisoner had previously brought a claim in state court and was awarded compensatory damages. The district court held that the state court compensatory damages award barred his [section] 1983 claim for punitive damages. The court found that the prisoner chose to litigate his claim in state court, where he was fully compensated for his injuries. A state claims court judge found that...