In November of 1979, inmates at the Madison County (Indiana) Jail brought a class action lawsuit under 42 U.S.C. § 1983 against the county board of commissioners and the county sheriff, alleging that the conditions in the jail violated their constitutional rights. They were seeking declaratory ...
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In November of 1979, inmates at the Madison County (Indiana) Jail brought a class action lawsuit under 42 U.S.C. § 1983 against the county board of commissioners and the county sheriff, alleging that the conditions in the jail violated their constitutional rights. They were seeking declaratory judgment, injunctive relief, and damages. On February 15, 1980, the United States District Court for the Southern District of Indiana (Judge William E. Steckler) entered judgment notwithstanding the verdict in favor of the inmates. The court approved a consent decree describing the conditions of the jail. Among these conditions were lack of heating and ventilation, unsanitary living conditions, inoperative bathroom facilities, and cockroach infestation. The jail also lacked policies regarding inmate classification and inmates' right to communicate with outsiders, including attorneys. The jail was overcrowded and violent criminals could not be segregated and inmates could not be properly supervised. The consent decree ordered the construction of a new facility and interim improvements in the existing facility. A jury had awarded the inmates significant damages and the district court, in entering its judgment, reduced that to nominal damages. The opinion from the district court is not available.
On May 9, 1980, following the death of an inmate, plaintiffs filed a petition requesting that the court determine whether the defendants were in compliance with the consent decree. In June of 1981, the district court found that although the defendants were not strictly complying with the decree, they were acting in good faith. In a later pre-trial conference, it was agreed that the class would be closed as of the June 1981 date. In a subsequent trial in November of 1983, a jury found that the jail did not meet minimum constitutional standards for some of the period after the consent decree was issued. The jury awarded damages in excess of half a million dollars. The district court again reduced the amount to nominal damages in a judgment notwithstanding the verdict, noting that plaintiffs cannot recover monetary damages for violations of constitutional rights in the absence of proof of actual harm.
On appeal, the Court of Appeals for the Seventh Circuit (Senior District Judge Jameson) affirmed the reduction in damages because there was not sufficient evidence of actual harm to the inmates to support the jury's award. Madison County Jail Inmates v. Thompson, 773 F.2d 834 (7th Cir. 1985).Angela Heverling - 03/06/2006