Case Citator › Louis Napier v. Karen J. Preslicka

Louis Napier v. Karen J. Preslicka

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Eleventh Circuit
Citation
314 F.3d 528
Decided
Confirmed treatments
1
Flagged citations read
73 of 73
Citing cases (total)
434
Treatment dates
2021
Overruled in part
A reviewed court has overruled part of this case’s holding. Louis Napier v. Karen J. Preslicka has been overruled in part. All 73 flagged citations have been read.
More on how this was screened

The 1 confirmed treatment is listed below. Sitting en banc, the Eleventh Circuit rejected Napier's sub silentio bar on punitive damages without physical injury under 42 U.S.C. § 1997e(e). Napier's separate holdings about what counts as custody and when a prisoner may seek compensatory damages for mental or emotional injury were not overruled there. The later screening orders largely apply those remaining holdings or report other courts' treatment.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

434 later cases cite Louis Napier v. Karen J. Preslicka; 73 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Louis Napier v. Karen J. Preslicka?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The en banc court overruled Napier insofar as it had barred punitive damages under the PLRA without physical injury.

    Hoever v. Marks · Eleventh Circuit (en banc) · filed

    In Napier v. Preslicka, 314 F.3d 528 (11th Cir. 2002), our Court again affirmed the dismissal of a punitive damages claim. Id. at 534. Because Napier did not specifically discuss punitive damages, our Court has described the case as a “sub silentio” ruling that the punitive damages claim was barred by the PLRA. Al-Amin, 637 F.3d at 1198–99. ... Because this Court’s precedents did not grapple meaningfully with the text of § 1997e(e), we now overrule those precedents in this regard.
    Read the full opinion on CourtListener →

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