Medina v. District of Columbia, No. 10-7094 (D.C. Cir. 2011)
Annotate this CasePlaintiff, the former captain of the Metropolitan Police Department (MPD), filed a ten-count complaint charging the District of Columbia with racial and ethnic discrimination and retaliation against him because of a series of discrimination complaints he filed against the MPD. At issue was whether plaintiff's damages award constituted impermissible double recovery, represented compensation for two distinct juries, or reflected a single award apportioned between two theories of liability. The court found that the magistrate judge explicitly instructed the jury not to concern itself with double recovery because he had concluded "as a matter of law" that plaintiff could recover under both his federal and state law theories. Therefore, the court held that it could not presume that the jury intended to compensate plaintiff for a single injury without regard to the multiplicity of the theories pled. Accordingly, because the jury's award amounted to impermissible double recovery, the court reversed the magistrate's order denying the District's motion for judgment as a matter of law and remanded the case.
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