Pitts v. Delaware, 2011 U.S. App. LEXIS 12215

Pitts sued Corporal Gregory Spence under 42 U.S.C. § 1983 and state law after a civil trial in which a jury awarded Pitts on two claims and Spence moved for judgment as a matter of law.
At the scene, Pitts, an African American man, disputed with Mitchem, a Caucasian shop owner, leading to a physical fight and subsequent threats against Pitts.
Wykpisz (Caucasian) chased Pitts with a bat; Pitts picked up a board for defense, and Mitchem later admitted damage to Pitts' car windshield and hood.
Spence detained Pitts, handcuffed him, and placed him in a patrol car without reading Miranda rights, and Pitts was taken to the police station where charges were filed.
Spence questioned Mitchem and Wykpisz and prepared reports, but did not interview Pitts at the scene; Pitts did not provide a statement to Spence.
The district court granted judgment as a matter of law for Spence on Pitts’ false arrest and equal protection claims, while Pitts’ appeal argued the jury verdicts were supported.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Pitts unlawfully seized in detention?	Pitts asserts detention lacked probable cause and relied on fear; jury could find unlawful detention.	Spence argues detention was reasonable given safety concerns and ongoing investigation.	Evidence supported unlawful seizure; jury could have found no probable cause.
Was the car tow and inventory search lawful?	Pretextual search; lack of probable cause; testimony shows pretext and improper motive.	Tow/search reasonable to prevent harm and follow procedure; no pretext.	District Court erred; evidence supported jury finding of unlawful seizure via towing/search.
Did Pitts establish equal protection violation?	Disparate treatment and discriminatory purpose/effect evident from Spence's conduct and reporting.	No evidence of discriminatory motive or effect; reporting differences were not proof of intent.	Evidence supported equal protection claim; error to discount discriminatory purpose/effect.
What standard governs reversal of a jury verdict under Rule 50?	Judgment should be reinstated if record supports jury verdict when viewed in Pitts' favor.	JMOL appropriate where record lacks minimum evidence.	Court reviews de novo; not to weigh credibility; record supports Pitts’ verdicts.
Should the district court's denial of fees be reinstated?	Pitts remains prevailing party for § 1988 fees.	No prevailing party after JMOL; deny fees.	Remand to consider fee motions on their merits.

Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (investigatory stops require reasonable suspicion)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (requiring rights advisement during custodial interrogation)
Acumed LLC v. Advanced Surgical Servs., Inc., 561 F.3d 199 (3d Cir. 2009) (standard for reviewing JMOL and evidentiary sufficiency)
Johnson v. Campbell, 332 F.3d 199 (3d Cir. 2003) (sparingly grant JMOL; review standards)
Mosley v. Wilson, 102 F.3d 85 (3d Cir. 1996) (duty to read verdicts harmonize inconsistencies)
City of Los Angeles v. Heller, 475 U.S. 796 (U.S. 1986) (verdict reading and consistency principles)