Watson v. City of San Jose, No. 13-15019 (9th Cir. 2015)
Annotate this CasePlaintiffs filed suit under 42 U.S.C. 1983 against San Jose police officers and others after the officers took the children into protective custody without a warrant or court order. On appeal, plaintiffs challenged the district court's grant of a new trial on compensatory and punitive damages. The court concluded that the district court did not err by concluding that a new trial was warranted. The jury instructions in the first trial may have permitted the jury to improperly award damages for deprivations for which defendants were not responsible. The court also concluded that the district court permissibly concluded that the jury awarded compensatory damages for emotional distress from the separation that was not caused by the police officers; the district court could likewise infer that the jury improperly punished the officers for that same separation. Because one of the factors used to examine the excessiveness of a punitive damages award is the amount of compensatory damages awarded, the district court did not abuse its discretion by concluding that a flawed compensatory damages award justified a retrial for punitive damages. Accordingly, the court affirmed the judgment.
Court Description: Civil Rights. The panel affirmed the district court’s decision to grant a new jury trial on compensatory and punitive damages in an action brought pursuant to 42 U.S.C. § 1983 against two San Jose police officers after the officers took plaintiffs’ minor children into protective custody without a warrant or court order. The panel held that because the jury instructions in the first trial may have permitted the jury to improperly award damages for deprivations for which defendants were not responsible, the district court did not err by concluding that a new trial was warranted. The panel agreed with the district court that the $3 million in damages awarded by the first jury indicated that the jury improperly awarded damages for the fact of separation of the children from their parents after a juvenile court entered a removal order. The panel held that the juvenile court order meant that the separation of the family was inevitable and could not be attributed to the police officers, and plaintiffs did not refute that proposition. Therefore, even if the jury concluded that the separation prior to the court order was not justified, the amount awarded by the first jury did not reasonably reflect the actual injury suffered as a result of a separation of five or six days, given that the separation for the 17 months that followed was lawful and would have occurred anyway. WATSON V. CITY OF SAN JOSE 3
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