An award of $12,000 in exemplary damages for a battery by correctional officers that left a handcuffed prisoner unconscious with a head wound was manifestly inadequate; $24,000 was substituted. Even a casual, seemingly disrespectful placement of a foot on an unconscious prisoner's leg, not explicable as a medical or restraint measure, constitutes a battery. A party cannot seek relief on appeal for a cause of action not pleaded or argued at trial.
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