Ecclesiastical
Denzel Washington was an inmate at Crossroads Correctional Center
(“Crossroads”) in Missouri.[1] He suffered from asthma and other respiratory
ailments that were aggravated by secondhand smoke.[2] While Crossroads was nominally a smoke-free
facility, in reality a large portion of the population smoked and were
permitted to do so in their cells.[3] This smoke-intensive environment aggravated
Washington’s condition, which led him to bring a 42 U.S.C. § 1983 action to
protect his Constitutional rights.[4]
Washington brought suit against a group
of prison officials alleging a violation of his Eighth Amendment right to be
free from cruel and unusual punishment.[5] Washington prevailed, collecting compensatory
and punitive damages in a federal district court.[6] A three-judge panel for the U.S. Court of
Appeals for the Eighth Circuit affirmed the jury’s findings of fact but vacated
the award of punitive damages and remanded the case for further proceedings on
damages.[7]
