Washington v. Denney, 5:14-cv-06118

Plaintiff Ecclesiastical Denzel Washington, an inmate at Crossroads Correctional Center since 2010, sued under 42 U.S.C. § 1983 alleging Eighth Amendment deliberate indifference to serious medical needs due to repeated exposure to secondhand smoke that exacerbates his asthma.
Washington presented medical records, testimony (including a physician deposition), inmate witnesses, and multiple grievances showing he repeatedly requested measures: nonsmoking cellmates, permitting a medical mask, and changes to smoking policy/enforcement.
Defendants (Denney, Pash, Prudden, Richey; Parkhurst was found for defendants at trial) denied his requests and appeals and admitted knowledge of his asthma and complaints; evidence showed continued smoking inside the facility and assignment of cellmates with prior smoking violations.
A jury returned verdicts for Washington against Denney, Pash, Prudden, and Richey, awarding $40,000 compensatory and $71,000 punitive damages in total; judgment entered and defendants moved for JMOL or a new trial.
The court reviewed whether the evidence could reasonably support findings of (1) objectively serious medical need and defendants’ knowledge and deliberate indifference, (2) causation of harm, and (3) punitive damages for reckless or callous indifference.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for §1983 Eighth Amendment liability	Washington: medical history, grievances, witness testimony, and defendant admissions show serious need and deliberate indifference	Defendants: evidence insufficient; plaintiff’s belief alone, conflicting evidence undermines liability	Denied JMOL — evidence was sufficient for a reasonable jury to find deliberate indifference
Causation (harm from defendants’ deliberate indifference)	Washington: physician testimony, his testimony, and eyewitnesses tied smoke exposure to increased asthma attacks	Defendants: disputed that plaintiff had asthma and that defendants’ conduct caused harm	Denied JMOL — record permitted reasonable jurors to find causation
Punitive damages (sufficiency for instruction and awards)	Washington: defendants acted with reckless or callous indifference warranting punitive damages	Defendants: insufficient evidence to support punitive damages instruction/award	Denied relief — sufficient evidence that defendants’ conduct was reckless/callous to support punitive awards
Motion for new trial / Qualified immunity raised in reply	Washington: trial verdict should stand; qualified immunity not timely raised	Defendants: alternatively sought new trial; later raised qualified immunity in reply	New trial denied; court refused to consider qualified immunity raised first in reply brief

E.E.O.C. v. Kohler Co., 335 F.3d 766 (8th Cir. 2003) (standard and deference for judgment as a matter of law motions)
Hunt v. Neb. Public Power Dist., 282 F.3d 1021 (8th Cir. 2002) (impropriety of overturning jury verdict absent complete absence of probative facts)
Johnson v. Hamilton, 452 F.3d 967 (8th Cir. 2006) (elements of § 1983 claim for deliberate indifference to serious medical need)
Letterman v. Does, 789 F.3d 856 (8th Cir. 2015) (deliberate indifference can be inferred where risk was obvious)
Krout v. Goemmer, 583 F.3d 557 (8th Cir. 2009) (obvious inadequacy of a response may support inference of officer’s recognition of risk)
Popoalii v. Crandell, 56 F.3d 35 (8th Cir. 1995) (prisoner must show more than negligence for Eighth Amendment medical claim)
Schaub v. VonWald, 638 F.3d 905 (8th Cir. 2011) (standards for awarding punitive damages under § 1983)