E-Alert Case Updates
Delaware Federal Court Examines Post-Trial Motion Standards Under Federal Rules of Civil Procedure 50, 59, and 60(b).
Amir Fatir v. Commissioner Stanley Taylor, et al.
Amir Fatir v. Commissioner Stanley Taylor, et al. involved a renewed motion for judgment as a matter of law and a motion for a new trial filed by a Plaintiff in a civil rights based case which resulted in a defense verdict. The United States District Court for the District of Delaware concluded that the verdict was not against the weight of the evidence produced at the trial, and thus, Judge Gregory M. Sleet denied Plaintiff’s motions.
By way of factual background, on November 15, 2006, Plaintiff Amir Fatir (“Plaintiff” or “Fatir”) brought a lawsuit against current and former Delaware Department of Corrections (“DOC”) employees Stanley Taylor, David Pierce, Janice Henry, James Satterfield, and Ronald Pawlowski (collectively, the "Defendants"). Plaintiff, an inmate in a Delaware DOC facility, asserted Eighth Amendment claims related to the inhumane conditions of confinement under 42 U.S.C. § 1983.
Trial was held in early July 2015. At trial, both Plaintiff and Defendants moved for judgment as a matter of law ("JMOL") pursuant to Rule 50(a) of the Federal Rules of Civil Procedure on a number of grounds; however, the Court denied the parties' dueling motions. On July 9, 2015, the jury returned a verdict in favor of the Defendants, and judgment was entered in favor of the Defendants on July 10, 2015. After judgment was entered, Plaintiff filed two (2) post-trial motions, asserting that he was entitled to judgment as a matter of law pursuant to Rule 50 of the Federal Rules of Civil Procedure or, alternatively, that he was entitled to a new trial pursuant to Rule 59 or Rule 60(b).
The Court began its analysis by explaining that in order to grant a renewed motion for judgment as a matter of law following a jury trial and verdict, a court must determine that the jury's findings, “presumed or express, are not supported by substantial evidence or, if they were, that the legal conclusion(s) implied by the jury's verdict cannot in law be supported by those findings.” Pannu v. Iolab Corp., 155 F.3d 1344, 1348 (Fed. Cir. 1998) (quoting Perkin-Elmer Corp. v. Computervision Corp., 732 F.2d 888, 893 (Fed. Cir. 1984)). The Court further explained that "Substantial evidence" is defined as "such relevant evidence from the record taken as a whole as might be accepted by a reasonable mind as adequate to support the finding under review." Perkin-Elmer Corp., 732 F.2d at 893. The Court noted that the question is “not whether there is literally no evidence supporting the party against whom the motion is directed, but whether there is evidence upon which the jury could properly find a verdict for that party." Lightning Lube v. Witco Corp., 4 F.3d 1153, 1166 (3d Cir. 1993)
The Court next explained that, pursuant to Federal Rule of Civil Procedure 59, a court may grant a new trial "for any of the reasons for which a new trial has heretofore been granted in an action at law in federal court," and that the decision to grant or deny a new trial is within the sound discretion of the trial court. See Fed. R. Civ. P. 59(a)(l)(A); Allied Chem. Corp. v. Daiflon, Inc., 449 U.S. 33, 36 (1980). The Court noted that unlike the standard for determining judgment as a matter of law, a court “need not view the evidence in the light most favorable to the verdict winner,” but a court should grant a new trial in a jury case only if "the verdict was against the weight of the evidence... and a miscarriage of justice would result if the verdict were to stand." See Allied Chem. Corp., 449 U.S. at 36; Williamson v. Conrail, 926 F.2d 1344, 1352 (3d Cir. 1991).
Similarly, the Court explained that Federal Rule of Civil Procedure 60 permits a court to grant a new trial due to "fraud..., misrepresentation, or other misconduct by an adverse party." Fed. R. Civ. P. 60(b)(3); see Bethel v. McAllister Bros., Inc., 81 F.3d 376, 384-85 (3d Cir. 1996). In order to prevail on a Rule 60 motion, the Court noted that the movant must show: (1) “that the adverse party engaged in fraud or other misconduct, and this conduct prevented the movant from fully and fairly presenting his case,” and (2) “that the fraud or misrepresentation was material to the outcome of the case.” See Stridiron v. Stridiron, 698 F.2d 204, 207 (3d Cir. 1983); Bandai Am. Inc. v. Bally Midway Mfg. Co., 775 F.2d 70, 73 (3d Cir. 1985). The Court further noted that fraud or misrepresentation must be proved by clear and convincing evidence. See Brown v. Pennsylvania R.R. Co., 282 F.2d 522, 527 (3d Cir. 1960).
The Court next discussed the substantive elements of Plaintiff’s claims, noting that the issue before it was whether the jury's finding of no deliberate indifference was supported by substantial evidence. The Court explained that an Eighth Amendment claim against prison officials must meet two (2) requirements: (1) “the deprivation alleged must be, objectively, sufficiently serious;” and (2) “the prison official must have been deliberately indifferent to the inmate's health or safety.” See Farmer v. Brennan, 511 U.S. 825, 834 (1994).
Under the first prong, the Court noted that a plaintiff must demonstrate that he has suffered a "sufficiently serious" constitutional deprivation, which means that a prison official's act or omission must result in the denial of "the minimal civilized measure of life's necessities." Id. at 834 (quoting Rhodes v. Chapman, 452 U.S. 337, 347 (1981)).
Under the second prong, the Court noted that a prison official "must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw the inference.” Farmer, 511 U.S. at 837. The Court explained, however, that "an Eighth Amendment claimant need not show that a prison official acted or failed to act believing that harm actually would befall an inmate; it is enough that the official acted or failed to act despite his knowledge of a substantial risk of serious harm." Id. at 842.
Regarding the first prong, Plaintiff argued that the trial evidence proved, as a matter of law, that that the conditions in the building in which he was housed, “D-Building,” were objectively, sufficiently serious and that this evidence was uncontested. Specifically, Plaintiff pointed to evidence of contaminated water, a lack of ventilation, dirty air, soiled mattresses that had bodily fluid stains, overheated cells, overcrowding, extended periods of confinement in the cell, mold in the showers, a cockroach infestation, and being forced to share cells with inmates having communicable diseases and mental illness. Plaintiff asserted that these conditions constituted deprivation of minimum necessities of life, and argued that the length of time during which he suffered from these conditions “amplified the degree of deprivation.”
Defendants responded that the conditions in D-Building were not inhumane, and argued that there was conflicting evidence as to whether conditions rose to the level of causing a serious deprivation. Ultimately, Defendants point out that faced with conflicting evidence about the prison conditions, a reasonable jury could have rejected evidence suggesting that the conditions were sufficiently serious.
Regarding the second prong, Plaintiff argued that the trial evidence proved, as a matter of law, that Defendants knew about the conditions in D-Building. Plaintiff and other inmates notified Defendants of the conditions in D-Building in person, through letters, and by filing grievances related to the problems in D-Building. Additionally, various prison accreditation standards suggested that D-Building was not meeting minimum standards for crowding. Plaintiff argued that this evidence, in addition to the fact that the Defendants failed to address the issues, proved, as a matter of law, that Defendants were deliberately indifferent to the conditions in D-Building.
The Defendants responded that under the deliberate indifference standard, Plaintiff must show that the Defendants believed the conditions posed an unreasonable risk of serious damage, and argued that there was conflicting evidence as to whether the officials knew that conditions rose to the level of causing serious harm. Defendants further argued that the evidence demonstrated that the Defendants did not ignore the conditions, but discussed solutions, solicited funding, submitted work orders, and used available means to remedy the problem.
After reviewing the facts of the case, the Court was not persuaded by Plaintiff’s arguments and agreed with Defendants that a reasonable jury could have concluded that Plaintiff did not meet the deliberate indifference standard. The Court noted that a reasonable jury could have found that the conditions while uncomfortable, did not create a substantial risk of harm nor deprive Plaintiff of "the minimal civilized measure of life's necessities." Farmer, 511 U.S. at 834 (quoting Rhodes v. Chapman, 452 U.S. 337, 347 (1981)). The Court explained that “the Constitution does not mandate comfortable prisons, and prisons… that house persons convicted of serious crimes, cannot be free of discomfort." Chapman, 452 U.S. at 349.
While Plaintiff argued that his case was different from other cases where a deliberate indifference claim was unsubstantiated because of the combined impact of multiple conditions, the Court was not persuaded. The Court believed that “the totality of the circumstances analysis is one that a jury is well equipped to make,” and concluded that it would “not substitute its view for that of the jury where a reasonable decision has been reached.” Additionally, even if the jury found that the conditions in this case were sufficiently serious, the Court noted that the jury still could have found that the Defendants were not aware of the substantial risk of serious harm or did not have the authority or funding to provide redress.
Accordingly, the Court concluded that the jury’s verdict in favor of Defendants was not against the weight of the evidence, and thus, denied Plaintiff’s renewed motion for judgment as a matter of law and motion for a new trial.
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