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Davis v. Rennie

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APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS [Hon. Morris E. Lasker, Senior U.S. District Judge]

Jason Davis, an involuntarily committed mental patient, brought suit under 42 U.S.C. � 1983, the Massachusetts Civil Rights Act, and other statutes against multiple defendants after being punched repeatedly in the head during a physical restraint at Westborough State Hospital. A jury awarded Davis $100,000 in compensatory damages and $1.55 million in punitive damages, concluding that the appellants violated Davis’s substantive due process rights under the Fourteenth Amendment. Joyce Wiegers, the head nurse who ordered the restraint, and Leonard Fitzpatrick, Richard Gillis, Michael Hanlon, Paul Rennie, and Nicholas L. Tassone, mental health workers who participated in the restraint, appeal the portion of the judgment against them. They argue that the district court erred in instructing the jury about Davis’s claims; that there is insufficient evidence for a reasonable jury to have found that they violated Davis’s constitutional rights; that they are entitled to qualified immunity; and that the evidence does not support a punitive damages award. We affirm the judgment against each of the appellants.

I.

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