Maira Guzman v. Marvin Bonnstetter, 689 F.3d 740

Guzman, seven-and-a-half months pregnant, was subjected to a large police/Special Task Force raid on June 14, 2005, after officers forcibly entered her home pursuant to a warrant.
Officers allegedly forced Guzman to lie face down and pressed her pregnant abdomen; approximately seventeen officers conducted an hour-long search.
Guzman sued under 42 U.S.C. § 1983 for unlawful search and seizure; district court granted summary judgment on several claims, and this court previously reversed on appeal regarding facial validity of the warrant.
On remand, the district court held a damages-only trial, where Guzman sought medical expenses and related harms from the alleged unlawful conduct.
During damages trial, the court admitted evidence and instructions aimed at liability, contrary to the damages-only scope, including a liability instruction and a nominal damages instruction benefitting Guzman but disputed by the defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether liability could be decided at a damages-only trial	Guzman argues liability should be kept out of damages phase to avoid confusion.	Bonnstetter and Rojas contend liability can be addressed implicitly and the instruction was harmless.	Liability instruction improperly given; prejudicial; remand for new damages trial.
Whether the nominal damages instruction was proper in a damages-only trial	Nominal damages may be warranted if no provable injury or credibility issues negate damages.	Nominal damages are appropriate where no compensable injury is proven, but require caution.	Nominal damages instruction may be appropriate on remand with careful explanation; remanded for new damages trial.
Did the erroneous liability instruction contaminate the damages trial	The jury could be misled into assessing liability rather than proximate causation of injuries.	The instruction merely clarifies liability; evidence shows damages occurred regardless.	Yes, the instruction likely confused the jury and affected damages determinations; reversible error.

Carey v. Piphus, 435 U.S. 247 (U.S. 1978) (damages for deprivation of rights; causation rules apply)
Herzog v. Village of Winnetka, 309 F.3d 1041 (7th Cir. 2002) (ordinary tort causation applies to constitutional torts)
Gile v. United Airlines, Inc., 213 F.3d 365 (7th Cir. 2000) (instruction error reviewed for prejudice and effect)
Happel v. Walmart Stores, Inc., 602 F.3d 820 (7th Cir. 2010) (remand for new trial in light of prejudicial verdict form/instructions)
Lewis v. City of Chicago Police Department, 590 F.3d 427 (7th Cir. 2009) (deference to jury instruction judgments; overall coherence assessed)
Kerman v. City of New York, 374 F.3d 93 (2d Cir. 2003) (loss of time damages; caution in nominal damages awards)
Randall v. Prince George’s Cnty., Md., 302 F.3d 188 (4th Cir. 2002) (loss of time award considerations)
Kyle v. Patterson, 196 F.3d 695 (7th Cir. 1999) (nominal damages as vindication of rights where no provable injury)