807 F.3d 6
1st Cir.2015Background
- Lund sued Henderson and Walcek for false arrest, excessive force, and related claims arising from an Aug. 22, 2008 incident in Wareham, MA.
- Lund alleged prior false arrests and excessive force by Henderson within the prior decade, seeking to admit them for motive and credibility.
- District court barred prior-act evidence against the two officers and bifurcated trials: liability against officers first, then claims against the Town and chief.
- Evidence showed Lund was injured at the scene and later diagnosed with degenerative disc disease; doctor did not causally link injuries to the arrest.
- Jury found no liability against Henderson or Walcek; district court dismissed Town and chief claims and denied Lund’s motion to amend to add an employee-negligence claim against the Town.
- Lund appeals the evidentiary rulings, bifurcation, denial of a new-trial motion, and denial of leave to amend.”
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prior complaints against Henderson were admissible | Lund argues prior acts show motive/intent. | Defendants contend Rule 404 bars propensity evidence and risks mini-trials. | Exclusion was proper; no abuse of discretion. |
| Whether bifurcation was improper management of the trial | Bifurcation prevented full proof of relevant claims. | Bifurcation allowed efficient trial and avoided unnecessary issues. | District court did not abuse discretion in bifurcation. |
| Whether the verdict against officers barred Town/chief claims | Victory against officers should not foreclose rest of case. | Monell-based and supervisory claims rely on officers’ conduct; no liability found. | Municipal liability defeated by jury verdict for officers. |
| Whether the district court abused its discretion denying leave to amend | Rule 15(b)(2) allows amendment to conform to evidence. | Undue delay and failure to show how claim fits the record. | Abuse of discretion in denying amendment. |
| Whether the district court erred in denying Lund’s weight-of-evidence challenge | Medical evidence supports Lund’s causation theory. | Record supports officer testimony; causation weak. | No abuse; verdict not against the weight of evidence. |
Key Cases Cited
- Monell v. Dep't of Soc. Servs., 436 U.S. 658 (U.S. 1978) (municipal liability requires official policy for §1983 claim)
- City of Los Angeles v. Heller, 475 U.S. 796 (U.S. 1986) (vicarious liability concerns and Monell doctrine)
- Gonzalez-Marin v. Equitable Life Assurance Soc'y of U.S., 845 F.2d 1140 (1st Cir. 1988) (trial management discretion and Rule 42 bifurcation)
- Onujiogu v. United States, 817 F.2d 3 (1st Cir. 1987) (Rule 403 balancing discretion in admission of evidence)
- Freeman v. Package Mach. Co., 865 F.2d 1331 (1st Cir. 1988) (evidentiary rulings reviewed for abuse of discretion)
- Wilson v. Town of Mendon, 294 F.3d 1 (1st Cir. 2002) (bifurcation and trial management precepts)
- Rodríguez-Soler v. United States, 773 F.3d 289 (1st Cir. 2014) (standard for reviewing trial-management decisions)