Arnold v. Wilder
657 F.3d 353
6th Cir.2011Background
- Incident occurred Oct. 25, 2003 in Kingsley, KY involving Arnold, her children, Wilder, and Strathmoor police based on Breuer’s complaints about children in yards.
- Arnold was arrested by Wilder after an escalation from a custody-assertion moment in her yard; she was dragged, handcuffed, pepper-sprayed, and taken to the station.
- Officers and bystanders testified inconsistently; DeCamillis and Armacost provided contextual testimony; Arnold’s daughter Caroline witnessed events.
- Arnold faced criminal charges (initial felonies later reduced to misdemeanors) and settlement discussions occurred; she ultimately proceeded to trial.
- District court later reduced Arnold’s punitive damages from $1,000,000 to $229,600, and Caroline’s IIED claim was dismissed; on appeal, court affirmed some rulings, modified punitive-damages, and remanded for entry of judgment.
- This opinion affirms in part, modifies punitive-damages reduction, and remands for judgment consistent with the ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was probable cause for Arnold’s arrest and prosecution | Arnold argues lack of probable cause; jury could find no crime based on pre-arrest conduct. | Wilder had probable cause for escape, resisting arrest, and hindering communication; Arnold fled custody and resisted arrest. | No reversible error; probable cause could be lacking; district court properly denied JML. |
| Whether Wilder continued or instituted the malicious-prosecution claim | Arnold contends Wilder instigated and pursued charges. | Prosecutor’s actions and dismissal can be influenced by others; but officer’s conduct can initiate prosecution. | Jury could find Wilder instituted or continued proceedings; supported denial of JML. |
| Whether the punitive-damages award was constitutionally excessive | Award was warranted given conduct and lack of full probable-cause defense; ratio should not be capped rigidly. | 4:1 ratio to compensatory damages is appropriate; the district court properly remitted. | Remittitur warranted but not at the district court’s exact four-to-one figure; punitive awarded reduced to 550,000 to keep ratio in single digits. |
| Whether the Rule 408 settlement evidence and cross-examination of lying-witness issues require a new trial | Evidence showed officer involvement in settlement discussions; could impact damages and claims. | Evidence was used to show Wilder’s involvement and potential bias; not intended to prove liability. | District court did not abuse discretion; any error harmless in light of other evidence. |
| Whether Caroline Arnold’s IIED claim was properly dismissed under Kentucky law | Caroline’s claim fits within even broad IIED theories if applicable; district court erred in limiting based on not adopting §46(2). | Kentucky had not adopted §46(2); conduct directed at Caroline lacked extreme or outrageous intent. | District court correctly granted JML; Kentucky has not adopted §46(2) and Wilder’s conduct not directed at Caroline. |
Key Cases Cited
- Sykes v. Anderson, 625 F.3d 294 (6th Cir. 2010) (false arrest requires lack of probable cause under Fourth Amendment principles)
- Pyles v. Raisor, 60 F.3d 1211 (6th Cir. 1995) (probable cause standard for arrests and related claims)
- Beck v. Ohio, 379 U.S. 89 (U.S. 1964) (probable cause and reasonable belief to arrest)
- Brendlin v. California, 551 U.S. 249 (U.S. 2007) (seizure for Fourth Amendment purposes evaluated at time of initial seizure)
- State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (U.S. 2003) (guidelines for evaluating punitive-damages awards (reprehensibility, ratio, disparity))
- Gore v. BMW of N. Am., Inc., 517 U.S. 559 (U.S. 1996) (non-mathematical, multi-factor approach to punitive damages; ratio guidance)
- Romanski v. Detroit Entm't, LLC, 428 F.3d 629 (6th Cir. 2005) (high punitive-to-compensatory ratio allowed in civil-rights cases with non-economic harm; damages ratio context)