Payne v. Jones
711 F.3d 85
| 2d Cir. | 2013Background
- Payne, a Vietnam veteran with PTSD, was brought to the emergency room for a cut finger and became combative, leading to Jones and Abel arresting him under New York Mental Hygiene Law § 9.41.
- At St. Elizabeth Medical Center Payne resisted transfer, Jones grabbed him in a bear hug and punched him after Payne kicked Jones; a nurse intervened and the attack lasted about 30 seconds.
- Payne alleged excessive force under 42 U.S.C. § 1983 and battery under New York law; a jury found in Payne’s favor on both claims.
- Jones missed the first three days of a five-day trial due to a medical emergency; the district court denied a continuance but proceeded with the trial.
- The jury awarded Payne $60,000 in compensatory damages and $300,000 in punitive damages; the district court later denied remittitur/adjustment and Jones appealed.
- The appellate court vacated the punitive damages award and remanded for a new trial on punitive damages unless Payne remits to $100,000.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Continuance denial standard | Payne argues denial prejudiced Jones | Jones contends continuance was required | No abuse of discretion; no prejudice shown |
| Punitive damages excessiveness | Payne/Payne argues amount appropriate | Jones argues $300,000 excessive | Punitive award excessive; remitted to $100,000 absent remittitur by Payne |
| Standards of review for excessiveness | Gore/Cooper standards support de novo review | Abuse-of-discretion standard applies | Review governed by abuse-of-discretion with Cooper dicta acknowledged |
| Role of guideposts in Gore analysis | Guideposts support high reprehensibility | Mitigating factors reduce reprehensibility | Reprehensibility factor supports reduction of punitive award |
| Relation to similar cases | Comparisons show higher awards acceptable | Cases show lower awards appropriate | Court finds $300,000 excessive compared to similar police-officer cases |
Key Cases Cited
- Davis v. United Fruit Co., 402 F.2d 328 (2d Cir. 1968) (trial continuances within court discretion)
- United States v. Cusack, 229 F.3d 344 (2d Cir. 2000) (broad discretion to grant or deny continuances)
- Morrissey v. National Maritime Union of America, 544 F.2d 19 (2d Cir. 1976) (deposition substitution when ill defendant; prejudice not shown)
- Cooper Industries, Inc. v. Leatherman Tool Group, 532 U.S. 424 (2001) (standard for reviewing punitive damages as constitutional excessiveness; de novo review)