Eric Watkins v. Broward County Sheriff
677 F. App'x 622
| 11th Cir. | 2017Background
- Eric Watkins, a pro se Florida pretrial detainee, filed a 42 U.S.C. § 1983 suit while in custody seeking compensatory (emotional) damages and declaratory/injunctive relief.
- The district court sua sponte dismissed the complaint while Watkins was incarcerated.
- Watkins appealed, challenging (1) dismissal of his damages claim for failure to allege physical injury and (2) dismissal of his declaratory and injunctive claims as moot.
- The Court of Appeals reviewed the sua sponte dismissal and mootness determinations de novo.
- The court applied the Prison Litigation Reform Act’s § 1997e(e) physical-injury requirement and mootness precedent regarding inmate transfers/releases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Watkins may recover compensatory damages for emotional distress under § 1997e(e) without alleging physical injury | Watkins sought emotional distress damages incurred while in custody | § 1997e(e) bars recovery for mental or emotional injury by prisoners absent prior showing of physical injury | Affirmed dismissal: § 1997e(e) forbids emotional-distress damages absent physical injury because Watkins was a "prisoner" when he filed |
| Whether declaratory and injunctive claims became moot after Watkins’ release and whether the capable-of-repetition-yet-evading-review exception applies | Watkins contended his requests for declaratory/injunctive relief should proceed | Release from custody deprives court of ability to provide meaningful relief; no demonstrated probability he will be subjected to same conditions again so exception doesn't apply | Affirmed dismissal as moot; exception inapplicable due to lack of demonstrated probability of recurrence |
Key Cases Cited
- Hughes v. Lott, 350 F.3d 1157 (11th Cir. 2003) (de novo review of sua sponte § 1915 dismissal and viewing complaint allegations as true)
- Harris v. Garner, 216 F.3d 970 (11th Cir. 2000) (§ 1997e(e) limitation applies to federal constitutional claims)
- CAMP Legal Defense Fund, Inc. v. City of Atlanta, 451 F.3d 1257 (11th Cir. 2006) (mootness reviewed de novo)
- Florida Ass'n of Rehab. Facilities, Inc. v. State of Fla. Dep't of Health & Rehab. Servs., 225 F.3d 1208 (11th Cir. 2000) (case is moot when court cannot give meaningful relief)
- Wahl v. McIver, 773 F.2d 1169 (11th Cir. 1985) (inmate's injunctive/declaratory claims become moot upon transfer)
- Arcia v. Sec'y of Fla., 772 F.3d 1335 (11th Cir. 2014) (elements of the capable-of-repetition-yet-evading-review exception)
- Murphy v. Hunt, 455 U.S. 478 (1982) (requirement of demonstrated probability for recurrence for exception to mootness)