Edwards v. Hartford, No. 17-3150 (2d Cir. 2020)
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Plaintiff filed suit against Officer May and the city, alleging excessive force, giving rise to a claim under 42 U.S.C. 1983, and various state law claims. A jury found in favor of plaintiff, awarding him compensatory and punitive damages. The district court granted the city's motion with respect to the punitive damages award but denied the motion with respect to the compensatory damages award.
The Second Circuit reversed and remanded, holding that the district court should have granted the city's motion with respect to all damages. The court agreed with the city that the district court misapplied CONN. GEN. STAT. 7‐465 because, in awarding punitive damages, the jury found that Officer May's actions in causing plaintiff's injuries were wilful or wanton, triggering an exception to section 7‐465's assumption of liability requirement for all damages attributable to Officer May's conduct.
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