Haynes v. Stephenson

GRUENDER, Circuit Judge.

Walter Haynes, an inmate incarcerated by the Arkansas Department of Corrections (“ADC”), prevailed on a retaliatory discipline claim under 42 U.S.C. § 1983 against Sergeant Patrick Stephenson, an ADC corrections officer. After a bench trial, the district court 1 awarded Haynes $1 in compensatory damages and $2,500 in punitive damages. Stephenson appeals, arguing that the district court erred in concluding that Haynes established a prima facie case of retaliatory discipline. He also argues that the punitive damages award violates the Due Process Clause of the Fourteenth…