Mejia v. Cook County, Ill.
2011 U.S. App. LEXIS 8316
| 7th Cir. | 2011Background
- Mejia sued Cook County and jail personnel under §1983 for excessive force from a Oct. 9, 2005 incident in Tier BJ of Cook County Jail; medical records show minor-to-moderate injuries.
- At trial, the jury ruled for the County; Mejia mov ed for a new trial arguing the verdict was against the weight of the evidence.
- The district court denied the motion, applying an “indisputable facts” standard, and concluded the verdict could not be set aside.
- On appeal, Mejia contends the district court used the wrong standard for a weight-of-the-evidence review, constituting error requiring remand.
- The Seventh Circuit vacates and remands to reconsider Mejia’s motion under the correct standard of law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the district court’s standard for a weight-of-the-evidence new-trial review correct? | Mejia argues the weight standard governs; court misapplied. | County contends the standard used was correct. | Remand for reconsideration under proper standard. |
| Did the district court improperly rely on the “indisputable facts” language to limit its weighing? | Evidence should be weighed for weight, not excluded as indisputable. | Language does not control the weighing, so error harmless? | Error to apply indisputable-facts constraint; remand required. |
| Should the case be remanded given district court’s misapplication rather than affirm/deny now? | Remand with instruction to grant new trial if weight supports it. | Outcome uncertain without proper standard; remand appropriate. | Remand to evaluate under correct standard; current record inconclusive. |
Key Cases Cited
- Gasperini v. Ctr. for Humanities, Inc., 518 U.S. 415 (1996) (new-trial standard; weight of the evidence authority)
- Byrd v. Blue Ridge Rural Elec. Coop., Inc., 356 U.S. 525 (1958) (court may assess weight and credibility on new-trial motion)
- Montgomery Ward & Co. v. Duncan, 311 U.S. 243 (1940) (scope of new-trial review; weight-based)
- Latino v. Kaizer, 58 F.3d 310 (7th Cir. 1995) (indisputable-facts concept limited to excluding evidence from weighing)
- United States v. Washington, 184 F.3d 653 (7th Cir. 1999) (weight of evidence includes witness credibility)
- Cefalu v. Village of Elk Grove, 211 F.3d 416 (7th Cir. 2000) (standard for weight-based new-trial review; deference to jury)
- Smith v. Northeastern Illinois Univ., 388 F.3d 559 (7th Cir. 2004) (considerations in evaluating trial credibility on appeal)
- Valbert v. Pass, 866 F.2d 237 (7th Cir. 1989) (standard balancing for weight-of-evidence)
- Smart Marketing Group v. Publications International Ltd., 624 F.3d 824 (7th Cir. 2010) (distinction between weight of evidence and judgment as a matter of law)