Martinez v. Carson, No. 11-2095 (10th Cir. 2012)
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In cross-appeals, the parties raised challenges to various rulings made by the district court in a section 1983 action arising out of an allegedly unlawful seizure. Defendants Gary Carson and Don Mangin, employees of the New Mexico Department of Corrections, observed Plaintiffs Phillip Martinez and Ricardo Sarmiento sitting or standing with a third man in a low-lit area outside an apartment building in a high-crime neighborhood at night. Defendants pulled up to the apartment building in an unmarked police car and turned on the emergency lights. Defendants forced Plaintiffs to the ground, handcuffed them, drew weapons, and conducted a pat-down search. When additional Rio Rancho officers arrived on the scene a few minutes later, Defendants transferred Plaintiffs, still in handcuffs, into the custody of these officers. The Rio Rancho police officers eventually arrested and booked Plaintiffs, holding Mr. Martinez for twelve hours and Mr. Sarmiento for five hours before their release. In their 1983 action, Plaintiffs raised claims of unlawful seizure against several Rio Rancho police officers as well as the named Defendants in this appeal. Defendants moved for summary judgment based on qualified immunity. The Rio Rancho defendants subsequently settled the claims against them and were dismissed from the action. Defendants filed a third motion for summary judgment and Plaintiffs filed a crossmotion for partial summary judgment. The district court denied both motions, citing multiple factual disputes. The court held that the pertinent question for the jury to decide was whether Defendants had reasonable suspicion of criminal activity when they detained Plaintiffs, and if so, the brief seizure was warranted as an investigative detention responsive to officer safety concerns; if not, it was an illegal seizure. The court further held that Defendants could only be held liable for their own allegedly unlawful conduct, not for the actions of the Rio Rancho officers. The case then proceeded to trial, where the jury found for Plaintiffs on their unlawful seizure claim, finding Defendants lacked reasonable suspicion to justify the initial seizure, and awarded Plaintiffs compensatory and punitive damages totaling $5,000 each. Plaintiffs appealed the district court's orders limiting Defendants' liability to the first few minutes of the seizure, as well as a discovery sanction. On cross-appeal, Defendants raised issues regarding (1) the district court's denial of summary judgment based on qualified immunity, (2) the district court's denial of their Rule 50(b) motion for judgment as a matter of law, (3) various evidentiary rulings the district court made at trial, and (4) the inclusion of a punitive damages jury instruction. Upon review, the Tenth Circuit affirmed the district court's sanctions order, reversed the district court's summary judgment order limiting Defendants' liability, and remanded the case back to the district court for a new trial limited to the issue of whether (and to what extent) Defendants reasonably should have known their unlawful seizure of Plaintiffs would have resulted in a prolonged detention and, if so, whether any additional damages were appropriate. Defendants' cross-appeal was dismissed.
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