Warren v. Pataki, No. 13-3412 (2d Cir. 2016)
Annotate this CaseDefendant, the former New York State Governor, launched the Sexually Violent Predator Initiative, which provided for the involuntary civil commitment at state psychiatric facilities of some ʺsexually violent predatorsʺ (SVPs) nearing the date of their release from incarceration or supervision. Plaintiffs, six individuals who were civilly committed to a psychiatric hospital, filed suit asserting claims under the Fourth Amendment, the substantive and procedural components of the Fourteenth Amendmentʹs Due Process Clause, the Fourteenth Amendmentʹs Equal Protection Clause, and several provisions of New York state law. The district court concluded that defendants were not entitled to qualified immunity as a matter of law, which the court affirmed on interlocutory appeal. Many of the claims were thereafter dismissed by the district court on judgments as a matter of law, while the remainder were tried to a jury. The jury found one defendant liable for procedural due‐process violations, and awarded each plaintiff one dollar in nominal damages against that defendant. On appeal, plaintiffs Warren and Brooks challenged the district courtʹs (1) jury instruction on personal involvement; (2) denial of judgment as a matter of law on procedural due‐process liability; (3) denial of judgment as a matter of law on plaintiffsʹ entitlement to actual, compensatory damages; (4) entry of judgment for the defendants on the plaintiffsʹ false‐imprisonment claims on the grounds that these claims were duplicative; and (5) limitations on depositions, and several other evidentiary decisions. The court concluded that plaintiffs' arguments lack merit and affirmed the judgment of the district court.
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