Smith v. Wade

Daniel Wade (plaintiff), an inmate at a Missouri reformatory for young offenders, was assaulted by his cellmates while in administrative segregation. Wade sued William Smith and four other correction officers (defendants) under 42 U.S.C. § 1983, alleging a violation of his Eighth Amendment right to freedom from cruel and unusual punishment. Wade claimed that Smith and the other officers knew or should have known that the assault was likely to occur because Wade had placed himself in protective custody due to prior violence against him, one of Wade’s cellmates was in segregation for fighting, and another inmate had been beaten to death just a few weeks before. Wade claimed that the officers did nothing to prevent the likely assault. The district court instructed the jury that to assert an Eighth Amendment claim that overcame the officers’ qualified immunity, Wade needed to show physical abuse so inhumane that it shocked sensibilities and show that the officers acted with at least gross negligence, meaning a callous indifference or thoughtless disregard for the consequences or an egregious failure to protect Wade. Ordinary negligence was insufficient. The judge also instructed that punitive damages were available if the officers’ conduct was in reckless disregard of or indifferent to Wade’s rights or safety. Four of the officers were held not liable, but the jury held Smith liable for both compensatory and punitive damages. Smith appealed the punitive-damages award, arguing that such damages could be awarded only if there was malicious intent. The court of appeals affirmed. The United States Supreme Court granted certiorari.