Morgan v. Tincher, No. 21-2060 (4th Cir. 2024)
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In this case from the United States Court of Appeals for the Fourth Circuit, the plaintiff, Frank Morgan, appealed from a decision of the United States District Court for the Southern District of West Virginia. Morgan alleged that a police officer, J.D. Tincher, used excessive force during his arrest and subsequent detention, causing him serious injuries. The case proceeded to a jury trial, and the jury found in favor of Officer Tincher.
However, after presenting his case, Morgan discovered another lawsuit against Officer Tincher, involving similar allegations of excessive force, which Tincher had failed to disclose during discovery. Morgan requested sanctions and moved for a new trial under Federal Rule of Civil Procedure 60(b)(3), alleging misconduct by the opposing party. The district court denied the motion, leading to this appeal.
In its decision, the Fourth Circuit held that Officer Tincher's failure to disclose the other excessive-force lawsuit constituted misconduct under Rule 60(b)(3). It also found that Morgan had presented a meritorious claim and that the misconduct prevented him from fully presenting his case. The court further concluded that the district court had erred in its analysis of whether the undisclosed evidence would have changed the trial outcome. Lastly, the court ruled that the interest of justice in this case outweighed the interest in the finality of judgments.
Therefore, the Fourth Circuit reversed the district court's decision, vacated the final judgment in favor of Officer Tincher, and remanded the case to the district court with instructions to allow for a reasonable period of additional discovery before conducting a new trial.
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