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Smith v. Wade
United States Supreme Court
461 U.S. 30 (1983)
Daniel Wade (plaintiff), an inmate at a Missouri state prison, was assaulted by his cellmates. Wade sued William Smith and four other guards and correctional officials (defendants) under 42 U.S.C. § 1983. Wade alleged that Smith and the other defendants knew or should have known that the attack was likely to occur but did nothing to prevent the assault. The trial court instructed the jury that punitive damages were available if the defendants’ conduct was in reckless disregard of or indifferent to Wade’s safety. The trial court also instructed the jury to apply a high standard for liability in general. In order to award damages, the jury had to find physical abuse of such base, inhumane, and barbaric proportions as to shock sensibilities. The jury also had to find the defendants guilty of (1) a callous indifference or thoughtless disregard for the consequences of their actions or failures to act or (2) a flagrant or remarkably bad failure to protect Wade. The jury determined that Smith was liable for both compensatory and punitive damages. Smith appealed the award of punitive damages, arguing that such damages could only be awarded based on malicious intent. The court of appeals affirmed. Smith petitioned the United States Supreme Court for review.
Rule of Law
Holding and Reasoning (Brennan, J.)
Dissent (O’Connor, J.)
Dissent (Rehnquist, J.)
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