Beard v. Wexford Health Sources, Inc.

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Wexford provides medical care to Illinois inmates. Beard experienced chronic ankle pain. In 2010 he consulted with his prison’s doctors, wanting surgery. The doctors ordered conservative treatment. When Beard’s pain persisted, the doctors considered referring Beard for surgical evaluation, which required Wexford’s approval. Wexford rejected requests for surgical evaluation but authorized Beard to see a podiatrist in 2012 and an orthopedist in 2015. Beard sued Wexford in 2011, claiming deliberate indifference to his serious medical need. A jury awarded Beard $10,000 in compensatory damages and $500,000 in punitive damages. The judge concluded that the punitive-damages award violated the Fourteenth Amendment’s prohibition on excessive or arbitrary punishment and reduced the award to $50,000. The Seventh Circuit vacated. While the Supreme Court has cautioned that “few awards exceeding a single-digit ratio between punitive and compensatory damages ... will satisfy due process,” the district court had nine single digits from which to choose and decided that the Seventh Amendment did not require it to offer Beard the option of a new trial before it entered judgment on the reduced award. The decision was arbitrary and constituted a procedural misstep. The court remanded to give Beard the choice between a reduced punitive-damages award and a new trial limited to damages. View "Beard v. Wexford Health Sources, Inc." on Justia Law