Anthony Boyd v. Joe Driver
495 F. App'x 518
5th Cir.2012Background
- Boyd, a federal prisoner, sues 13 BOP employees under Bivens for due process violations arising from an assault prosecution, resulting in his acquittal.
- Plaintiff alleges the defendants manufactured evidence, tampered with videotape, and gave perjured testimony at his federal trial.
- On remand from this court’s prior decision, the district court dismissed, questioning whether Boyd adequately alleged a due process claim without a conviction.
- This court previously held Boyd’s pro se complaint states a Castellano-based direct due process claim despite acquittal and remanded for further proceedings.
- The district court later held that (a) lack of a wrongful conviction defeats the claim, (b) no physical injury bars compensatory damages under PLRA, and (c) no punitive damages for recklessness.
- The panel reverses, holding that Castellano allows a due process claim regardless of acquittal and that nominal and punitive damages may be pursued; PLRA bars only compensatory damages.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Castellano allow a due process claim despite acquittal? | Boyd's complaint states direct due process claims under Castellano. | Castellano requires a wrongful conviction to state a due process claim. | Yes; Castellano claims survive acquittal; remand proper. |
| Can Boyd recover compensatory damages given PLRA? | Castellano claims allow damages for mental suffering. | PLRA bars compensatory damages without physical injury. | Compensatory damages barred; nominal/punitive damages allowed. |
| Are punitive damages available for Castellano-based due process claims? | Defendants acted with reckless indifference to rights. | Punitive damages require more explicit showing; district court dismissed. | Punitive damages are available; defendants’ conduct satisfies recklessness/evil intent. |
Key Cases Cited
- Castellano v. Fragozo, 352 F.3d 939 (5th Cir. 2003) (manufacturing of evidence and perjured testimony can support a due process claim)
- Boyd v. Driver, 579 F.3d 513 (5th Cir. 2009) (Castellano-based direct due process claim stated despite acquittal)
- Gen. Universal Systems, Inc. v. HAL, Inc., 500 F.3d 444 (5th Cir. 2007) (mandate rule; agency on remand must follow appellate directives)
- Hutchins v. McDaniels, 512 F.3d 193 (5th Cir. 2007) (PLRA § 1997e(e) does not bar nominal/punitive damages)
- Williams v. Kaufman County, 352 F.3d 994 (5th Cir. 2003) (reckless indifference required for punitive damages; evil intent standard)
- Sockwell v. Phelps, 20 F.3d 187 (5th Cir. 1994) (recklessness standard for punitive damages in §1983 actions)
- Geiger v. Jowers, 404 F.3d 371 (5th Cir. 2005) (PLRA damages framework for mental/emotional injury)