Masters v. Runnels, No. 19-2199 (8th Cir. 2021)
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Plaintiff filed suit under 42 U.S.C. 1983, alleging that defendant, a police officer, used excessive force against him during a traffic stop. A jury found in favor of plaintiff, awarding compensatory and punitive damages. Defendant appealed.
The Eighth Circuit concluded that, viewing the facts in the light most favorable to the verdict, defendant's prolonged use of his taser was not an objectively reasonable use of force. In this case, although plaintiff initially resisted defendant's attempts to remove him from the car, he did not physically hit or verbally threaten defendant. Furthermore, plaintiff, who was 17 years old at the time, posed at most a minimal safety threat to defendant. The court also concluded that plaintiff's right to be free from excessive, prolonged use of a taser was clearly established at the time. Accordingly, the court affirmed the district court's denial of defendant's motion for judgment as a matter of law on the prolonged taser claim.
The court rejected defendant's evidentiary claims of error, concluding that the district court did not abuse its discretion in admitting testimony from a vocational rehabilitation expert and testimony from an economist based on the vocational expert's opinion. Finally, the court concluded that the district erred in reducing the punitive damages award. While the court concluded that the district court correctly found that the jury's initial punitive damages award was disproportionate, the court disagreed that the reduced award of $236,500 sufficiently reflected the reprehensibility of defendant's conduct. In this case, the 9:1 ratio comports with due process while achieving the statutory and regulatory goals of retribution and deterrence. Accordingly, the court affirmed in part, reversed in part, and remanded.
Court Description: [Kelly, Author, with Colloton and Melloy, Circuit Judges] Civil Case - Civil Rights Act. A jury found police officer Runnels used excessive force against Masters during a traffic stop. Runnels appeals denial of qualified immunity and error in admission of expert testimony and Masters appeals reduction of punitive damages award. Masters claimed Runnels's firing a taser into his chest, prolonging the taser discharge and picking him up while unconscious and dropping him face-first onto concrete violated his Fourth Amendment rights. Prolonged use of taser was not objectively reasonable in light of circumstances that Masters was an unarmed suspected misdemeanant, did not resist arrest, did not threaten or attempt to flee and did not behave aggressively. Right to be free from excessive, prolonged use of taser was clearly established. Thus, denial of motion for judgment as a matter of law on the prolonged taser claim was not error. District court did not abuse its discretion in admitting vocational rehabilition expert, as he based his opinion on medical records, educational record and employment history and there was sufficient undisputed evidence to support opinion; or in admitting testimony of economist based on the vocational expert's opinion. District court erred in reducing the punitive damages award; a ratio of 9:1 comports with due process and while achieving statutory and regulatory goals of retribution and deterrence and award of $425,700 is imposed. Judge Colloton concurs.
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