MANHATTAN (CN) - A former Rikers Island inmate who saw his prison term extended from three weeks to three years after fighting with corrections officers is entitled to a new trial on his retaliation claim because a federal court wrongfully excluded evidence, the Second Circuit ruled.
Axel Rentas was sent to Rikers Island after being convicted of a misdemeanor. In July 2007, he got in a fight with corrections officers after he refused to move to a new bed.
Rentas claimed officers punched, kicked, and used pepper sprayed on him, and continued to beat him even after they'd gotten him into handcuffs.
He says he suffered a fractured eye socket, internal bleeding, and bruises all over his body, and the corrections officers also complained of injuries.
Rentas sued New York City, the prison warden and several corrections officers, alleging civil rights violations, but corrections officers also took action, filing a report that led to multiple counts of felony assault against Rentas, which led to three more years behind bars.
Capt. John Ruffin, a defendant in the case, had presented testimony from other Rikers inmates that Rentas started the 2007 fight.
Rentas was released from Rikers in 2010, and immediately refiled his lawsuit, claiming staff at the prison of faked records and prisoner testimony related to a fight, and that he'd been the victim of excessive force and malicious prosecution. He also sought to refute claims by the officers he had started the 2007 fight by asserting that at the time, he did not have any bruises or abrasions on his hands.
A federal judge dismissed the malicious prosecution and excessive force charges, but a jury later found against corrections officers for violating Rentas' right to a fair trial and for infliction of emotion distress, awarding him $67,000 in damages.
Both sides appealed. Rentas tried to reinstate his malicious prosecution charges, and the corrections officers sought to dismiss Rentas' claims of intentional infliction of emotional distress, claiming there was no medical evidence to support such a claim.
In a March 8 opinion, the Second Circuit ruled that the lower court was right to dismiss the malicious prosecution charges because Rentas could not prove the absence of probable cause. However, the three-judge panel also found the trial court was wrong to not to exclude the corrections officers' reports because they amounted to hearsay.
"The submission of false reports was the principal way in which Rentas could show that the defendants interfered with his right to a fair trial," Judge Raymond Lohier wrote. "They were central to Rentas's fair trial, excessive force, and failure to intercede claims ... [and] there is a substantial likelihood that their erroneous exclusion affected the outcome of the trial."
The panel also ruled that the district court was correct in instructing the jury to award Rentas nominal instead of compensatory damages. "We are less certain that the nature and cause of Rentas's injuries were undisputed, particularly where, as here, both justified and excessive force was arguably used," Lohier wrote.
Rentas emotional distress claims also remain, as the Second Circuit found his hospital records - which indicated anxiety, stress, and depression - were enough evidence to allow the charges to proceed.
The case now goes has been remanded back to the trial court, where Rentas will again try to make the case the corrections officers faked reports to extend his prison stay.
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