Micah Riggs v. Robert Gibbs, 66 F.4th 716

On Oct. 3, 2012 KCPD officers conducted a warrantless search of Micah Riggs’ Coffee Wonk, seizing cash and suspected synthetic marijuana; Riggs was criminally charged but ultimately the state dropped all charges.
Riggs sued under 42 U.S.C. § 1983 alleging an unconstitutional search and a pattern of harassment by KCPD officers; district court denied qualified immunity and case proceeded to trial on the Fourth Amendment claim.
At trial the jury found for Riggs only on the § 1983 claim against Detective Robert Gibbs; the verdict form required at least $1.00 if damages had no monetary value and the jury wrote $1.00.
During jury-instruction conferences Riggs requested punitive-damages instructions; the district court declined to give them initially but said it would reconsider if the jury found for Riggs (bifurcated approach). Riggs did not object to that procedure.
After the verdict, Riggs did not renew his request for punitive damages or move for a new trial; he appealed the district court’s failure to instruct on punitive damages. The Eighth Circuit reviewed for plain error and affirmed the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred by not instructing the jury on punitive damages	Riggs argued the evidence showed reckless indifference and the court should have given punitive-damage instructions	Defendants argued the evidence did not support punitive damages and the court properly deferred instruction until after liability	No reversible error; court reviewed for plain error and affirmed (no miscarriage of justice)
Proper standard of review for failure to give punitive-damage instruction	Riggs urged de novo review of the district court’s refusal to submit punitive damages	Defendants emphasized preservation rules and that no definitive district-court ruling was made	Court held de novo review inappropriate because Riggs failed to preserve; reviewed under plain-error standard

Riggs v. Gibbs, 923 F.3d 518 (8th Cir. 2019) (prior interlocutory appeal dismissed for lack of jurisdiction)
Thurairajah v. City of Fort Smith, Ark., 3 F.4th 1017 (8th Cir. 2021) (standard for reviewing punitive-damages instruction)
Torbit v. Ryder Sys., Inc., 416 F.3d 898 (8th Cir. 2005) (review standard for jury instructions)
Bauer v. Curators of Univ. of Mo., 680 F.3d 1043 (8th Cir. 2012) (waiver of jury-instruction objections absent plain error)
May v. Nationstar Mortg., LLC, 852 F.3d 806 (8th Cir. 2017) (policy against covertly preserving objections for appeal)
Westcott v. Crinklaw, 133 F.3d 658 (8th Cir. 1998) (review of nominal verdict adequacy; plain injustice standard)
Bady v. Murphy-Kjos, 628 F.3d 1000 (8th Cir. 2011) (plain-error review is stringently limited in civil cases)
Slidell, Inc. v. Millennium Inorganic Chems., Inc., 460 F.3d 1047 (8th Cir. 2006) (plain-error requires showing miscarriage of justice)
Coleman v. Rahija, 114 F.3d 778 (8th Cir. 1997) (liability under § 1983 does not automatically warrant punitive damages)