WASHINGTON -- The Supreme Court gave a Maryland prison inmate a small, but promising, victory yesterday in his continuing legal plea for more money damages because a doctor and prison guards allegedly neglected his medical needs.
In a unanimous ruling, the court took one step toward reviving the federal court appeal of William Lewis Smith, now at the Roxbury Correctional Institution. Smith has won $15,000 in damages, but a reinstatement of his appeal would allow him to seek more.
The court's decision may also have given prison inmates across the country new assurance of some leeway if the legal papers they file in federal court do not satisfy precisely the often technical rules of those courts.
Steven H. Goldblatt, a Georgetown University professor who acted as Smith's lawyer at the Supreme Court, said the ruling "makes it pretty clear" that the court has not abandoned its long-standing view that federal courts' procedural rules should be interpreted "liberally" and not with rigid precision.
The court, Mr. Goldblatt said, had raised some doubts in comments it made in a decision three years ago about whether it would continue to allow those procedural rules to be bent in order to keep a case alive.
If the papers filed can serve as the "functional equivalent" of the kind of document a court rule demands, cases should not be thrown out of federal court simply for failure to submit exactly the same document as is specified by the rules, the court declared in an opinion by Justice Sandra Day O'Connor.
In the Smith case, the inmate, acting as his own lawyer, had filed a legal brief in the 4th U.S. Circuit Court of Appeals in Richmond, when what he was supposed to have filed, under court rules, was a formal notice that he was going to appeal his case. As a result of his mistake, his appeal was thrown out.
The Supreme Court said the Circuit Court's ruling was wrong. It then ordered that court to reconsider whether the paper that Smith did file was sufficient to serve as a notice of appeal.
Smith's case, filed originally more than nine years ago, claimed that a doctor who treated prison inmates, two prison staff psychologists, and six guards all had denied him access to . .TC wheelchair when he needed one because an illness prevented him from walking or standing up.