## Facts

- Daniel R. Wade, an inmate at a Missouri reformatory, had previously been assaulted by other inmates and had been in protective custody.
- Wade was later housed in punitive and administrative segregation.
- Guard William H. Smith placed additional inmates into Wade’s cell despite known risks, including that one was in segregation for fighting and that serious violence had recently occurred at the facility.
- Wade was harassed, beaten, and sexually assaulted by his cellmates.
- In Wade’s 42 U.S.C. § 1983 action alleging failure to protect in violation of the Eighth Amendment, the jury was instructed that compensatory liability required gross negligence or an egregious failure to protect (not mere negligence).
- The jury was instructed that punitive damages could be awarded if Smith acted with reckless or callous disregard of, or indifference to, the rights or safety of others.
- The jury found Smith liable and awarded compensatory and punitive damages; other officials were exonerated.
- The Eighth Circuit affirmed, and the Supreme Court granted review on the punitive-damages standard under § 1983.

## Issues

1. Whether punitive damages are available in actions brought under 42 U.S.C. § 1983.
2. Whether punitive damages under § 1983 require proof of evil motive or intent, or may also be based on reckless or callous indifference to federally protected rights.
3. Whether punitive damages may be awarded on a recklessness standard when the underlying compensatory-liability standard is also recklessness or gross negligence.

## Decision

- The Supreme Court affirmed.
- Punitive damages are available in a proper case under § 1983.
- A jury may award punitive damages when the defendant’s conduct is motivated by evil motive or intent, or when it shows reckless or callous indifference to the plaintiff’s federally protected rights.
- This threshold for punitive damages applies even when the standard for compensatory liability is also recklessness; punitive damages remain discretionary.

## Legal Principles

- Section 1983 incorporates background common-law tort rules concerning damages unless displaced by statutory text or purpose; punitive damages were widely available at common law at the time of § 1983’s enactment.
- Punitive damages in § 1983 cases may be based on reckless or callous indifference to federally protected rights and are not limited to conduct driven by actual malice.
- A higher mental state than the compensatory-liability standard is not categorically required for punitive damages; juries may impose punitive damages as an additional sanction based on the degree and circumstances of the misconduct.
- Doctrines such as qualified immunity and the discretionary nature of punitive awards operate as safeguards against excessive chilling of official conduct.

## Conclusion

The Court held that punitive damages may be awarded in § 1983 actions upon a showing of evil motive or intent or reckless or callous indifference to federally protected rights, and that this punitive standard can apply even when compensatory liability also turns on recklessness.


Smith v. Wade, 461 U.S. 30 (1983)