Punitive damages against governments
Dean v. Bond
In brief
- Where it stands
- Dismissed
Petition denied.
- What it’s about
- Austin Bond, representing Terral Ellis’s estate, sued Sheriff David Dean over Ellis’s alleged denial of medical care in the Ottawa County Jail.
- Who it affects
- The Tenth Circuit's decision remains in place for Dean and Ellis's estate, but the Supreme Court did not decide whether the new-trial ruling or damages questions were legally correct.
Summary: written with AI from the case record.
What it's about
After a jury awarded $33 million, Dean argued that the jury had been improperly urged to punish him and sought a new trial; the Supreme Court refused to hear his petition (denied review) and did not decide the legal questions.
Ellis's estate sued Dean over an alleged denial of medical care in the Ottawa County Jail. Dean argued that the jury had been improperly urged to punish him.
Dean's petition raised questions about new trials and punitive damages in a lawsuit under a federal civil-rights law.
Question presented
1. Whether the Tenth Circuit Court of Appeals erred in denying a new trial to Petitioner. 2. Whether the Tenth Circuit’s Order is contrary to the precedent established in City of Newport v. Fact Concerts, Inc. , 453 U.S. 247, 101 S.Ct. 2748, 69 L.Ed.2d 616 (1981) that punitive damages cannot be awarded against a governmental entity in a 42 U.S.C. § 1983 lawsuit. 3. Whether the Tenth Circuit’s Order is contrary to the precedent established in Gasperini v. Center for Humanities, Inc. , 518 U.S. 415, 116 S.Ct. 221, 135 L.Ed.2d 659 (1996) that a court has a duty to grant a new trial when it appears the jury has acted based on an improper motive.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Brief added: Petition
Sources
Primary materials from the Court and the parties. Grounded in docket records and cited sources. Official filings and opinions remain authoritative.