Adams v. Roberts
| Decision Date | 11 August 2021 |
| Docket Number | CV 18-148-M-DLC |
| Parties | BRENDAN E. ADAMS, an individual, Plaintiff and Counter Defendant, v. HOWARD C. ROBERTS, an individual, Defendant and Counter Claimant. |
| Court | U.S. District Court — District of Montana |
Following an altercation on a dirt road in northwestern Montana Plaintiff and Counter Defendant Brendan E. Adams sued Defendant and Counter Claimant Howard C. Roberts alleging battery, trespass, and intentional infliction of emotional distress. Roberts, in turn, asserted counterclaims against Adams for assault and false imprisonment. The case went to trial, and the jury returned a verdict in favor of Roberts on the false imprisonment claim, awarding him both compensatory and punitive damages. On the remaining claims and counterclaims, the jury determined neither party succeeded.
Now before the Court is Adams' Motion for Relief Under Rules 50 & 59, and to Extend Automatic Stay. (Doc. 105.) Adams joins his motion for judgment as a matter of law, under Federal Rule of Civil Procedure 50, with his alternative motion for remittitur or a new trial, pursuant to Federal Rule of Civil Procedure 59. See Smith v. City and Cnty of Honolulu, 887 F.3d 944, 949 (9th Cir. 2018). He adds that the Court could also amend its judgment, under Rule 59(e), and to the extent applicable, Rule 52(b).
For the following reasons, the Court denies Adams' request for post-trial relief.
Background[1]
On July 12, 2017, Roberts crossed Adams' property on Lake Mary Ronan via an easement road (the “Easement”) to reach land owned by Lance Melton on the Easement's south end. Roberts was looking for his daughter, Lindsay, who had called him in distress following a heated interaction she had with Adams and his family stemming from her own use of the Easement. When Roberts reached the Melton property and exited his truck, he turned to see Adams approaching him on a four-wheeler.
At trial, the parties disputed what happened next. Adams testified that Roberts grabbed him by the throat and threw him to the ground. Roberts countered that any physical contact he made with Adams was to prevent Adams from using the four-wheeler to pin him against his truck. In any event Adams eventually drove his four-wheeler back to the north end of the Easement, where the Easement meets the public road. Once there, Adams parked the four-wheeler such that it blocked anyone from exiting the Easement.
As such, when Roberts drove his truck back across the Easement toward the north end, he found his return to the public road blocked. Roberts dialed 911, informed authorities that Adams prevented him from leaving, and returned to Lance Melton's property at the south end of the Easement pursuant to the dispatcher's instructions. Once Roberts parked, someone-Adams or one of Adams' family members-moved the four-wheeler from where it sat blocking the north end of the Easement to the block the Easement's south end, where it accessed Lance Melton's property.
The evidence showed Adams then sat in a lawn chair in the middle of the Easement. Though Adams testified that the alleged “beating” he took from Roberts left him dazed, a photograph revealed that Adams sat comfortably with his legs crossed while he talked on his cellphone and reviewed documents contained in a file folder. Meanwhile, Adams' sister sat in another lawn chair on the Easement, this one positioned in front of the four-wheeler, facing Roberts where he stood waiting for authorities on the Melton property. Adams' wife and son stood nearby, shouting back and forth with Roberts. Eventually, law enforcement arrived at the scene and the parties dispersed.
Adams filed suit in this Court, invoking diversity jurisdiction pursuant to 28 U.S.C. § 1332(a); at the time the action commenced Adams was a citizen of Oregon and Roberts was a citizen of Montana, and Adams alleged that the amount in controversy exceeded $75, 000.[2] (Doc. 1 at 1-2.) As outlined already, Adams asserted three intentional tort claims against Roberts: battery, [3] trespass, and intentional infliction of emotional distress. Roberts counterclaimed, alleging two intentional tort claims of his own-assault and false imprisonment or unlawful restraint-and seeking more than $100, 000 in damages. (Doc. 4 at 7-8.) Additionally, Roberts contended that any force he used against Adams was justified to protect himself. (Docs. 4 at 4; 64 at 4-5.) Neither party moved for summary judgment, and the case proceeded to trial on all claims and counterclaims.
After a five-day trial, the jury returned a verdict in favor of Roberts on his false imprisonment counterclaim, awarding $100, 000 in compensatory damages and finding him entitled to punitive damages on the same. (Doc. 93.) However, the jury found against Roberts on his assault counterclaim, and, as expressed in the verdict form, concluded that Adams failed to prove his battery, trespass, and intentional infliction of emotional distress claims by a preponderance of the evidence. (Id.) In the same form, to which neither party objected, the jury concluded that Roberts was justified in using force against Adams. (Id. at 1.)
After the jury was polled on the verdict form and ordered to return to the jury room, the Court conferred with the parties on punitive damages. Counsel for Adams and Roberts declined the Court's invitation to proffer any evidence on the issue instead deciding to proceed directly to argument. The jury returned, the parties argued, and the Court again excused the jury to deliberate. After about 20 minutes, the jury returned with a verdict for $750, 000 in punitive damages on Roberts' false imprisonment claim. Three days after the jury was discharged, and pursuant to Federal Rule of Civil Procedure 58, the Court ordered entry of judgment in favor of Roberts on his false imprisonment claim, against him on the assault claim, and against Adams on all three of his tort claims. (Docs. 97, 98.) Then, as required by Montana statute, the Court reviewed and affirmed the jury's punitive damage award. (Doc. 102.)
Now, Adams moves for judgment as a matter of law or a new trial, or, alternatively, an amended judgment as it relates to the Court's affirming the punitive damage award. (Docs. 106, 114.) In support of the latter, Adams files a Declaration regarding his net worth. (Doc. 106-1.) Finally, Adams requests an extension of the automatic stay of execution of the judgment.
Adams moves for judgment as a matter of law under Federal Rule of Civil Procedure 50(b), [4] or a new trial pursuant to Rule 59(a) or an amended judgment pursuant to 59(e). As discussed further below, different standards apply to each Rule Adams invokes, but the Constitution underpins them all. It is worth remembering, in other words, that parties to suits in common law are guaranteed “the right of a trial by jury . . . and no fact tried by a jury, shall be otherwise reexamined in any court of the United States.” U.S. Const. amend. 7. Thus, as it considers Adams' request to be relieved from the jury's two unanimous verdicts in this case, the Court bears in mind that constitutional principles disfavor granting the relief he seeks, at least to the extent he asks the Court to reevaluate facts properly found by the jury. See 9B C. Wright & A. Miller, Federal Practice and Procedure § 2522, pp. 227-29 (3d ed. 2008) ().
As he did at the close of the defense's case at trial, Adams argues that the Court should grant judgment as a matter of law on Roberts' false imprisonment claim based on insufficient evidence. And because the jury returned a punitive damage award based on the same purportedly unsupported claim, Adams adds that the Court should render judgment as a matter of law on the punitive damage award as well.
Rule 50 directs a court to render judgment as a matter of law when “a party has been fully heard on an issue during a jury trial and the court finds that a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on that issue.” Fed.R.Civ.P. 50 (a)(1). Out of respect for the sanctity of the jury's verdict, a court must uphold the verdict if it is supported by “substantial evidence.” Wallace v. City of San Diego, 479 F.3d 616, 624 (9th Cir. 2007). A court must review all the evidence in the record and draw “all reasonable inferences in favor of the nonmoving party, and it may not make credibility determinations or weigh the evidence.” Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150 (2000).
Importantly, because credibility and evidentiary weight are the jury's province, a court “must disregard all evidence favorable to the moving party that the jury is not required to believe.” Id. at 150-51. In other words, courts considering Rule 50 motions “should give credence to the evidence favoring the nonmovant as well as that evidence supporting the moving party that is uncontradicted and unimpeached, at least to the extent that that evidence comes from disinterested witnesses.” Id. at 151 (emphasis added).
Here, although Adams advances three arguments in support of judgment notwithstanding the verdict, all of them would require the Court to weigh the evidence, make credibility determinations, or reach absurd legal conclusions. The Court addresses each argument in turn.
First Adams says,...
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