Lamont Heard v. Tom Finco, 930 F.3d 772

Four Michigan inmates (Heard, Johnson, Moses, Nelson), members of the Nation of Islam, alleged prison officials reduced Ramadan meal portions beginning in 2009, impairing their ability to fast and engage in spiritual practices.
Inmates sued under the First and Eighth Amendments; the jury found constitutional violations and awarded compensatory damages totaling $900 ($150 per disrupted Ramadan per inmate as applicable).
Inmates moved for a new trial on damages, arguing the award failed to account adequately for spiritual harms; the district court denied the motion.
Defendants did not challenge liability on appeal; the appeal concerns whether the district court abused its discretion by denying a new-trial motion on the adequacy of damages.
The record included inmate testimony, medical records, and expert testimony (a nutritionist and an Islamic studies scholar) about physical and spiritual harms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the damages award was inadequate as a matter of law	Jury undervalued spiritual harms; award too low given evidence	Award was within jury's discretion and supported by evidence	Denied — district court did not abuse discretion; award supported by competent evidence
Whether spiritual (intangible) harms require objective proof (e.g., medical records) to justify higher damages	Spiritual injuries alone justify greater damages without medical proof	Lack of objective medical/psychological treatment justified modest award	Court: juries may award for intangible harms; absence of objective records may explain lower award but does not preclude recovery
Standard for granting a new trial on damages	Jury verdict was unsupported and plaintiffs unquestionably entitled to more	Verdict need only be supported by some competent, credible evidence	Applied Sixth Circuit standard; plaintiffs failed to show entitlement to higher damages under Anchor/Walker standard
Deference to jury credibility findings, including expert testimony	Plaintiffs urged court to credit their experts and testimony more heavily	Defendants emphasized jury was entitled to weigh credibility and evidence	Court reinforced deference to jury credibility and that trial court should not substitute its judgment if verdict reasonably reached

Anchor v. O’Toole, 94 F.3d 1014 (6th Cir. 1996) (new-trial-on-damages reversal requires plaintiffs to unquestionably prove entitlement to more)
Walker v. Bain, 257 F.3d 660 (6th Cir. 2001) (verdict need only be supported by some competent, credible evidence)
King v. Zamiara, 788 F.3d 207 (6th Cir. 2015) (no precise formula exists for compensatory damages; amount is for factfinder)
Smith v. Heath, 691 F.3d 220 (6th Cir. 2012) (amount of compensatory damages left to sound discretion of factfinder)
Wayne v. Village of Sebring, 36 F.3d 517 (6th Cir. 1994) (trial court should deny new trial if verdict reasonably could be reached)
McDonald v. Petree, 409 F.3d 724 (6th Cir. 2005) (witness and expert credibility decisions are solely for the jury)
United States v. L.E. Cooke Co., 991 F.2d 336 (6th Cir. 1993) (credibility determinations lie with factfinder)