Medina v. District of Columbia
395 U.S. App. D.C. 409
D.C. Cir.2011Background
- Angel Medina, a Hispanic MPD captain, sues DC for racial discrimination and retaliation under federal law and the DC Human Rights Act stemming from 1994, 1997-98, and 2001 incidents.
- Incidents: 1994 transfer from Internal Affairs to street duties after promotion; another White officer transferred back while Medina was not.
- Late 1997–early 1998: two Caucasian officers chosen for Internal Affairs instead of Medina’s request to return there.
- 2001: Medina suspended without pay pending criminal charges; later acquitted and argues improper severity and delay in reinstatement.
- Jury verdict awarded Medina $180,000 total for retaliation claims (two theories: federal and DC law) across five remaining counts; other counts were dismissed.
- District court denied remittitur; magistrate concluded no double recovery; this court reverses and remands for remittitur or new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the verdict constitutes impermissible double recovery | Medina argues separate federal and DC-law awards reflect two injuries. | District contends two theories yield a single injury, allowing double recovery. | Double recovery occurred; remittitur or new trial required. |
| What injury Medina suffered and which theory tracked it | Injury is emotional distress from retaliation; federal and DC claims share the same injury. | Injury could be framed as separate rights violations under different theories. | Only one injury; injuries were not distinct enough to justify separate awards. |
| Did the jury apportion a single injury between two theories or award duplicative damages | The jury allocated damages across theories; Medina prevailed under both. | Remittitur should allocate or restrict to avoid duplicative compensation. | No valid apportionment shown; damages duplicative for same injury. |
| Appropriate remedy for double recovery | Remittitur not required if proper allocation occurred. | Remittitur or new trial necessary to cure double recovery. | Remittitur of $90,000 (or new trial) ordered. |
Key Cases Cited
- Kassman v. American Univ., 546 F.2d 1029 (D.C.Cir. 1976) (no double recovery in absence of punitive damages)
- Snowden v. D.C. Transit Sys., Inc., 454 F.2d 1047 (D.C.Cir. 1971) (no more than actual loss without punitive damages)
- Mason v. Okla. Turnpike Auth., 115 F.3d 1442 (10th Cir. 1997) (two theories with same facts may not double recover)
- U.S. Indus., Inc. v. Touche Ross & Co., 854 F.2d 1223 (10th Cir. 1988) (same operative facts; identical relief = double recovery)
- Martini v. Federal National Mortgage Ass'n., 178 F.3d 1336 (D.C.Cir. 1999) (distinguishes punitive damages from compensatory double recovery; allocation possible)
- Monell v. Dep't of Soc. Servs. of N.Y., 436 U.S. 658 (U.S. 1978) (policies or customs as basis for § 1983 claims)