Arthur Taylor, Jr. v. Dave Dormire
690 F.3d 898
8th Cir.2012Background
- Taylor, a prisoner, sued Missouri prison officials under 42 U.S.C. § 1983 for denying him food while he was restrained.
- Policy at Jefferson City Correctional Center allowed an inmate to declare an enemy, resulting in removal to a restraint bench and meal denial unless in a cell, with limited water and medical exceptions.
- From Sep 9 to Sep 14, 2005, Taylor remained shackled on a restraint bench for days while prison officials followed the policy and did not feed him.
- Taylor experienced stomach pains, lightheadedness, headaches, and weakness; he first ate on Sep 15 after missing about twelve meals.
- During trial, Taylor sought nominal damages and an excessive force instruction; the district court gave an excessive force instruction but denied nominal damages, and Taylor prevailed in the district court's judgment for the defendants.
- On appeal, the court reversed and remanded to provide a nominal damages instruction; a concurrence argued the district court also erred by not giving a deliberate indifference instruction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether nominal damages must be instructed | Taylor entitled to nominal damages if awarded but no monetary injury could be shown. | Harmless error since verdict favored defendants; damages not necessary for verdict. | Reversed; district court abuse for not instructing nominal damages; remanded |
| Whether deliberate indifference instruction was required | Deliberate indifference standard applicable to denial of food in confinement context. | Policy-based restraint context fits safety/discipline framework; no need for deliberate indifference instruction. | Not decided by majority; concurrence would address on remand |
Key Cases Cited
- Cowans v. Wyrick, 862 F.2d 697 (8th Cir.1988) (nominal damages required when damages cannot be monetized)
- Foulk v. Charrier, 262 F.3d 687 (8th Cir.2001) (nominal damages instruction supported by rule for excessive force cases)
- Holloway v. Alexander, 957 F.2d 529 (8th Cir.1992) (harmless error rejected when damages were considered by jury)
- Lee v. Andersen, 616 F.3d 803 (8th Cir.2010) (elements of damages in excessive force context; instructive framework)
- Pirani, 406 F.3d 543 (8th Cir.2005) (en banc consideration of harmless error in damages instruction)