Latest Case: Williams v. Marinelli (Civil Rights)

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SHERRY F. COLB

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DEAN FALVY

Dean Falvy, a lecturer at the University of Washington School of Law in Seattle, offers thoughts on the legal tactics and briefs filed by each side in former President Trump’s second impeachment trial. Mr. Falvy argues that if Trump can survive a second impeachment vote, it will show that he is still operating where he has always believed himself to be: well beyond the reach of the law.

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Williams v. Marinelli

Docket: 18-1263

Opinion Date: February 4, 2021

Judge: Leval

Areas of Law: Civil Rights, Constitutional Law

Plaintiff, a Connecticut inmate, filed suit under 42 U.S.C. 1983 against defendant and other Connecticut state officials, alleging deprivation of his Eighth Amendment rights. A jury found defendant liable for violating plaintiff's constitutional rights and awarded plaintiff compensatory and punitive damages. At issue in this appeal is the satisfaction of plaintiff's judgment. After the judgment became final, the State voluntarily undertook to satisfy the judgment on defendant's behalf. In doing so, the State took actions against plaintiff under Connecticut law to recoup portions of the payment. The Second Circuit affirmed the district court's rulings on plaintiff's "motion for aid of judgment" and "motion to unfreeze assets," as well as defendant's motion for reconsideration and "motion for credit against judgment." The court concluded that the Eleventh Amendment did not bar the district court's ruling that defendant's debt to plaintiff had not been satisfied. The court also concluded that the district court did not err in concluding that Connecticut's actions were preempted by section 1983. In this case, the court found no error in the district court's conclusion that the State's attempt to discharge defendant's judgment obligations in significant part through payments to itself and payments to plaintiffs that the state might eventually recoup undermines the objectives of section 1983. Likewise, defendant's motion for reconsideration also failed for the same reasons as the district court's ruling on plaintiff's post-judgment motions. Finally, defendant waived his challenge to the district court's denial in part of his motion for credit against judgment.