126 F.4th 1264
7th Cir.2025Background
- Plaintiff Blake Stewardson was arrested for DUI on New Year's Eve 2018 and transported to Cass County Jail, Indiana.
- At the jail, Officer Titus used substantial force against Stewardson, including multiple head slams, a leg sweep, and a hip toss; Biggs, a supervising officer, witnessed some of these incidents and failed to intervene.
- Stewardson sustained injuries and filed a lawsuit under 42 U.S.C. § 1983 for excessive force (against Titus and Biggs) and Monell liability against Cass County.
- The district court granted summary judgment for defendants on most claims, but sent two to trial: excessive force against Titus and failure-to-intervene against Biggs. Jury found Titus liable (awarding both compensatory and significant punitive damages), but found for Biggs on failure-to-intervene.
- Titus appealed the punitive damages as unconstitutional; Stewardson cross-appealed summary judgments dismissing other claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of punitive damages | $850,000 punitive damages against Titus justified by repeated, malicious excessive force | Damages excessive and violate due process; should be reduced | Award not unconstitutionally excessive; affirmed |
| Qualified immunity for Biggs (knee strikes) | Biggs used disproportionate force, violating clearly established rights | Knee strikes were objectively reasonable in context; law not clearly established otherwise | Biggs entitled to qualified immunity on this claim |
| Qualified immunity for Biggs (failure-to-intervene) | Biggs should have intervened to prevent Titus’s later hip toss | Cannot be liable for failing to intervene when not present; law unclear on duty to intervene in such circumstances | Biggs entitled to summary judgment; law not clearly established |
| Monell liability (Cass County policy) | Cass County had a custom of unconstitutionally stripping uncooperative detainees | No proof of widespread practice, just single incident | No triable issue; summary judgment for County |
Key Cases Cited
- Smith v. Wade, 461 U.S. 30 (U.S. 1983) (punitive damages may be awarded under § 1983 for conduct driven by evil motive or reckless indifference)
- State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (U.S. 2003) (outlines guideposts for constitutional limits on punitive damages, including reprehensibility and ratio to compensatory damages)
- Monell v. Dep't of Social Services, 436 U.S. 658 (U.S. 1978) (local governments only liable under § 1983 for constitutional violations resulting from official policy or custom)
- Kingsley v. Hendrickson, 576 U.S. 389 (U.S. 2015) (excessive force in pretrial context evaluated by objective reasonableness under Fourteenth Amendment)
- Est. of Moreland v. Dieter, 395 F.3d 747 (7th Cir. 2005) (upheld large compensatory and punitive damages awards in excessive force case)
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (courts may consider qualified immunity's second prong—clearly established law—before the constitutional violation prong)
- Florence v. Bd. of Chosen Freeholders, 566 U.S. 318 (U.S. 2012) (strip searches in jails can be constitutional under certain circumstances)