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Gonsalves v. City of New Bedford

United States District Court for the District of Massachusetts · Civil Procedure

Civil ProcedureRule 50Rule 59Rule 49(a)special verdictinconsistent verdictsjudgment as a matter of lawnew trial

Facts

The jury found that Leonard Baillargeon beat Morris Pina at Mapleview Terrace and awarded $5,000 for that harm. The jury also found that at least one defendant used unreasonable force against Pina at police headquarters and that at least one defendant intentionally or with deliberate indifference failed to attend to Pina's serious medical need, and that both were proximate causes of his death. The jury could not determine which individual defendant committed the headquarters constitutional violations because each Phase One defendant had engaged in an intentional cover-up. The jury therefore awarded $430,000 in damages for the cover-up, for which all Phase One defendants were held jointly and severally liable.

Issue

Whether the evidence was sufficient to support the jury's findings of excessive force, denial of medical care, and intentional cover-up; whether the special verdict answers were impermissibly inconsistent because the jury found intentional constitutional violations without identifying the individual violators; and whether defendants were entitled to qualified immunity on the Section 1983 cover-up claim.

Rule

Under Rule 50, judgment as a matter of law may be granted only if, viewing the evidence and reasonable inferences in the light most favorable to the plaintiff and without weighing credibility, there is insufficient evidence for a reasonable factfinder to do more than guess as to a material fact. Under Rule 59, a new trial may be granted only if the verdict is against the clear weight of the evidence such that upholding it would result in a miscarriage of justice. A viable Section 1983 claim exists for an intentional cover-up when government officials intentionally conceal facts in order to frustrate the plaintiff's ability to discover and prove constitutional violations, the concealment actually causes the plaintiff's inability to obtain the damages she otherwise would have recovered on a meritorious claim, and the conduct therefore deprives the plaintiff of adequate, effective, and meaningful access to the courts.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a federal civil rights trial in Boston, Elena Cruz alleges that county jail officers beat her brother and ignored his obvious medical distress. Two eyewitnesses support Elena, but three officers deny any assault, and the defense expert offers a different cause of death. After the jury finds for Elena, the officers move for judgment as a matter of law.

How should the court rule on the Rule 50 motion?

Explanation. Under Rule 50, the court must view the evidence and reasonable inferences in the light most favorable to the nonmovant, and it may not assess credibility, resolve conflicts in testimony, or weigh the evidence. Judgment as a matter of law is proper only if the evidence is insufficient for a reasonable factfinder to do more than guess concerning a material fact. Because competing testimony and expert disagreement still permit a reasonable jury finding for Elena, the motion should be denied. (Derived from Gonsalves v. City of New Bedford (n.d.).)