—who secured a finding that two prison guards caused him to drop head first from the back of a pickup truck while his hands were shackled, id., 936 F. 2d at 1211, or the plaintiff in

When jailers continue to use substantial force against a prisoner who has clearly stopped resisting—whether because he has decided to become compliant, he has been subdued, or he is otherwise incapacitated—that use of force is excessive.

—an inmate, after attempting to escape, was recaptured and confined in a dog cage in the back of a truck with his hands shackled behind his back.

We have explained that "[a] n award of punitive damages is authorized in a civil rights case if `the defendant was motivated by an evil motive or intent, or there [was] reckless or callous indifference to federally protected rights,'"

A jury considered whether the prison guards violated the inmate's constitutional rights by, among other things, placing the inmate in the dog cage and, upon removal from the cage, causing the inmate to fall from the back of the truck.

—but should include time spent on all claims that arise out of the same course of conduct and share a "common core of fact," even if a specific individual claim did not succeed.

Even in the absence of compensatory damages, the evidence supports a conclusion that [the defendants] acted with reckless or callous indifference to [the plaintiff's] constitutional rights. Accordingly, the jury's award of punitive damages was proper and will not be disturbed on appeal. "(citations omitted

The other circuits that have considered this issue unanimously follow the rule announced in Basista.[9] See

The law of the Eleventh Circuit "prohibit [s] the use of excessive force by a prison guard against an inmate" who is restrained and "pose [s] no continuing threat."

The product of the reasonable hourly rate and the reasonable hours expended is known as the lodestar calculation.