Kidis v. Reid, No. 19-1673 (6th Cir. 2020)
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Kidis, driving home, after drinking heavily, caused a minor accident, exited his vehicle, and fled. Officer Reid attempted to arrest Kidis; he fled with a handcuff attached to his wrist. He jumped barbed-wire fences before entering a wooded area. Eventually, Kidis surrendered, lying face down, his hands stretched out above his head. Kidis asserts that Officer Moran thrust his knee into Kidis, punching and strangling Kidis, yelling that he was going to “teach [him] to . . . run.” Kidis pleaded guilty to resisting and obstructing a police officer, operating a motor vehicle with high blood-alcohol content, and failing to stop at the scene of an accident.
Kidis filed a 42 U.S.C. 1983 action against both officers. Rejecting Kidis’s deliberate indifference claim, the court found that Kidis could not prove that either officer was aware of Kidis’s medical needs. The court rejected an excessive force claim against Reid. A jury found that Moran used excessive force but that Kidis did not prove that this force caused his injuries. The jury awarded Kidis $1 in compensatory damages and $200,000 in punitive damages. The court rejected the officers’ motions for attorneys’ fees but awarded Kidis $143,787.97 in fees. The Sixth Circuit reversed the punitive damages award but otherwise affirmed. Measured against the harm and compensatory damage findings, the punitive damages award runs afoul of due process principles. On remand, the court is to reduce the award to no more than $50,000.
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