City of Hartford v. Edwards, 011020 FED2, 17-3150

Docket Nº:17-3150
Opinion Judge:WESLEY, Circuit Judge:
Party Name:CITY OF HARTFORD, Defendant-Appellant, v. KENVILLE EDWARDS, Plaintiff-Appellee, MATTHEW CORNELL, OFFICER, ERIC BAUMGARTEN, JAMES ROVELLA, CHRISTOPHER MAY, OFFICER, Defendants, FABIAN EDWARDS, KEITHMICHAEL MITTO, ELIZABETH EDWARDS, Plaintiffs.
Attorney:NATHALIE FEOLA-GUERRIERI, Office of the Corporation Counsel, Hartford, CT, for Defendant-Appellant. JAMES J. HEALY, Cowdery & Murphy, LLC, Hartford, CT (Peter M. Van Dyke, Eagan, Donohue, Van Dyke & Falsey, LLP, West Hartford, CT, on the brief), for Plaintiff-Appellee.
Judge Panel:Before: WESLEY, CHIN, AND SULLIVAN, Circuit Judges.
Case Date:January 10, 2020
Court:United States Courts of Appeals, Court of Appeals for the Second Circuit
 
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CITY OF HARTFORD, Defendant-Appellant,

MATTHEW CORNELL, OFFICER, ERIC BAUMGARTEN, JAMES ROVELLA, CHRISTOPHER MAY, OFFICER, Defendants,

v.

KENVILLE EDWARDS, Plaintiff-Appellee,

FABIAN EDWARDS, KEITHMICHAEL MITTO, ELIZABETH EDWARDS, Plaintiffs.[*]

No. 17-3150

United States Court of Appeals, Second Circuit

January 10, 2020

Argued: September 9, 2019

NATHALIE FEOLA-GUERRIERI, Office of the Corporation Counsel, Hartford, CT, for Defendant-Appellant.

JAMES J. HEALY, Cowdery & Murphy, LLC, Hartford, CT (Peter M. Van Dyke, Eagan, Donohue, Van Dyke & Falsey, LLP, West Hartford, CT, on the brief), for Plaintiff-Appellee.

Before: WESLEY, CHIN, AND SULLIVAN, Circuit Judges.

Defendant-Appellant City of Hartford appeals from a judgment of the United States District Court for the District of Connecticut (Garfinkel, M.J.) entered following a jury trial. After an altercation in June 2012 involving the Plaintiff- Appellee Kenville Edwards and Christopher May-a Hartford Police Officer- Edwards brought a civil suit against Officer May and the City alleging excessive force, giving rise to a claim under 42 U.S.C. § 1983, and various state law claims. A jury found for Edwards and awarded him compensatory and punitive damages. Under Connecticut law, the City was required to pay damages on behalf of Officer May so long as his actions were not wilful or wanton. After trial, the City filed a motion for judgment as a matter of law to avoid the assumption of liability. The district court granted the City's motion with respect to the punitive damages award but denied the motion with respect to the compensatory damages award. Hartford argues on appeal that the district court should have granted the City's motion with respect to all damages. We agree. Accordingly, we REVERSE the district court's judgment and REMAND for the district court to enter judgment for Hartford and for further proceedings consistent with this opinion.

WESLEY, Circuit Judge:

Defendant-Appellant City of Hartford, Connecticut (the "City" or "Hartford") appeals from a judgment of the United States District Court for the District of Connecticut (Garfinkel, M.J.) entered following a jury trial.1 This case involves a confrontation between Hartford Police Officer Christopher May and Plaintiff-Appellee Kenville Edwards that resulted in injuries to Edwards and a suit alleging civil rights violations against the City and Officer May. In his complaint and at trial, Edwards argued that Officer May acted wilfully or wantonly by using excessive force to arrest him, giving rise to a claim under 42 U.S.C. § 1983. Edwards also contended that the City, pursuant to Conn. Gen. Stat. § 7-465, was liable to pay any compensatory damages for his injuries arising from the arrest.2

The jury found for Edwards on the excessive force claim and awarded him both compensatory and punitive damages. The City filed a motion for judgment as a matter of law to avoid the assumption of liability for all damages on the grounds that the jury found Officer May's actions to be wilful or wanton. The district court granted the City's motion with respect to the punitive damages award only.

Hartford argues on appeal that the district court misapplied section 7-465 because, in awarding punitive damages, the jury found that Officer May's actions in causing Edwards's injuries were wilful or wanton, triggering an exception to section 7-465's assumption of liability requirement for all damages attributable to Officer May's conduct. We agree. Accordingly, we reverse the district court's judgment and remand for the district court to enter judgment for Hartford on its motion for judgment as a matter of law and for further proceedings consistent with this opinion.

BACKGROUND

The relevant facts and procedural history giving rise to this appeal are largely undisputed. In short, a June 2012 altercation between Edwards and Officer May resulted in injuries to Edwards and his arrest. Edwards filed a complaint alleging several state law claims and civil rights violations against Officer May, including use of excessive force pursuant to 42 U.S.C. § 1983. The complaint also brought claims against the City for assumption of liability under section 7-465, which directs Connecticut municipalities to pay for civil judgments against its employees so long as the employee acted in the performance of his duties, within the scope of his employment, and provided his actions were not wilful or wanton.

Ultimately, a jury found in favor of...

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