Christopher Parish v. City of Elkha, 702 F.3d 997

Parish, imprisoned for eight years based on eyewitness identification, alleged a due process violation under § 1983.
The jury found liability for wrongful imprisonment but awarded only $73,125 compensatory and $5,000 punitive damages.
The district court admitted some testimony and excluded key innocence evidence, affecting damages.
Post-verdict, Parish moved for a new trial alleging the damages were irrational and evidence was improperly limited.
The Seventh Circuit affirmed liability, vacated damages, and remanded for a new damages trial, citing Rule 403 and innocence-evidence errors.
The case centers on whether the damages award was reasonably based and whether the district court erred in restricting innocence evidence during the damages phase.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether innocence evidence was improperly excluded at damages trial	Parish sought broad innocence evidence.	Exclusion was appropriate under 403 to avoid prejudice.	District court abused discretion; exclusion improper.
Whether the damages award should be reversed or remanded	Damages were an outlier and lacked rational basis.	Damages could be sustained if liability proved.	New trial on damages required; liability affirmed.
Whether the court erred in upholding liability while vacating damages	Liability supported by evidence.	Damages flawed due to evidentiary errors.	Liability affirmed; remand for damages only.

Whitehead v. Bond, 680 F.3d 919 (7th Cir. 2012) (Rule 403 and evidentiary balancing guiding abuse of discretion review)
Boros v. United States, 668 F.3d 901 (7th Cir. 2012) (probative value vs. prejudice in Rule 403 balancing)
Cobige v. City of Chicago, IL, 651 F.3d 780 (7th Cir. 2011) (damages retrial where evidentiary errors affected liability or damages)
United States v. Miller, 688 F.3d 322 (7th Cir. 2012) (prejudice vs. probative value standard in 403 analysis)