John Legrand v. United States
698 F. App'x 55
| 3rd Cir. | 2017Background
- John Legrand, a former inmate at USP Canaan, sued the United States under the FTCA for injuries from a June 2011 salmonella outbreak at the prison.
- The United States conceded liability for salmonella poisoning; the case proceeded to a bench trial on damages.
- Legrand claimed physical illness from salmonella and sought both compensatory and emotional-distress damages.
- Post-incident medical testing attributed Legrand’s ongoing digestive symptoms to GERD and a hiatal hernia, not to the salmonella exposure.
- The District Court awarded $2,500 in damages for the salmonella injury but denied any emotional-distress award; Legrand appealed both rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Entitlement to emotional-distress damages | Legrand contends fear of permanent digestive damage from the salmonella caused compensable emotional distress | Government notes medical tests showed GERD and hiatal hernia caused symptoms; emotional distress from unrelated illness is not recoverable | Court affirmed denial: emotional distress must be tied to defendant-caused injury; here tests showed unrelated conditions, so no recovery |
| Adequacy of monetary award ($2,500) | Legrand argues $2,500 was insufficient given his suffering | Government and district court relied on comparable inmate awards, lack of medical expenses/lost wages, and record evidence that Legrand exaggerated symptoms | Court affirmed: under abuse-of-discretion/"shocks the conscience" standard, the award was not so inadequate to warrant reversal |
Key Cases Cited
- DeJesus v. U.S. Dep’t of Veterans Affairs, 479 F.3d 271 (3d Cir. 2007) (standards for reviewing legal and factual issues in FTCA actions)
- Tyminski v. U.S., 481 F.2d 257 (3d Cir. 1973) (appellate standard for disturbing monetary awards: reversal only if award is plainly inadequate)
- Williams v. Martin Marietta Alumina, Inc., 817 F.2d 1030 (3d Cir. 1987) (articulating that awards will not be reversed unless they "shock the conscience")
- Lubowitz v. Albert Einstein Medical Ctr., N. Div., 623 A.2d 3 (Pa. Super. Ct. 1993) (emotional-distress recovery is not available for illnesses unrelated to defendant's fault)