Judge upholds punitive damage award in prison strip search

A judge rejected a challenge on Monday by Delaware’s Department of Correction of a jury’s $15,000 punitive damage award to an inmate who was mistreated by a former prison guard during a strip search.

The judge upheld the jury’s November decision to award punitive damages to Richard M. Chamberlain, who is serving time following his seventh drunken-driving arrest in 2016.

The jury found that correctional officer George Pyle intentionally made physical contact with Chamberlain during the 2017 strip search that was harmful or offensive and unnecessary to enforce prison procedures. Jurors determined that Pyle engaged in "outrageous conduct" and that he acted in bad faith with "gross or wanton negligence."

Pyle denied touching Chamberlain, while simultaneously arguing that if he did touch him, it was in accordance with prison rules.


A state attorney representing Pyle challenged the jury verdict, arguing that state law provides immunity from liability for an employee acting in good faith, without gross negligence and within the scope of his duties. According to the state, the only evidence of wrongdoing was that Pyle snapped his gloves, grinned or smirked and said, "It’s strip search time."

Judge Paul Wallace denied the motion to overturn the jury’s findings and rule that Pyle was immune from liability.

"It appears the jury could reasonably, and did, reject Officer Pyle’s testimony as to both his behavior and his lack of bad faith," Wallace wrote.

Wallace also refused to reduce or vacate the punitive damage award.

"No argument has been presented that the jury’s verdict was based on passion, prejudice, or misconduct," Wallace wrote, adding that the award was within "an acceptable range."