Priscilla Rainey v. Jayceon Taylor, 941 F.3d 243

Plaintiff Priscilla Rainey, a contestant on a VH1 reality show, alleged that defendant Jayceon Taylor sexually assaulted her at a Chicago-area bar in 2015 by lifting her skirt, groping her breasts and genitalia, and exposing her to onlookers.
A recorded, multi-angle video captured a heated post-incident confrontation on the show’s tour bus in which Taylor told Rainey to "shut up," threatened her, and used profanity; Rainey described the assault on camera.
Rainey sued Taylor for sexual battery in federal court; Taylor repeatedly evaded service, delayed litigation, and engaged in vitriolic social-media attacks after the suit was filed.
At trial Taylor failed to appear; his counsel sought continuances citing a claimed dental emergency and offered flight/hotel reservations, while Rainey introduced Snapchat images suggesting Taylor was partying instead of preparing for trial.
The district court denied continuances, gave a missing-witness (adverse-inference) instruction, admitted the tour-bus video over Rule 403 objections, and the jury awarded $1.13 million in compensatory and $6 million in punitive damages to Rainey.
The district court denied Taylor’s post-trial motions (new trial, remittitur); the Seventh Circuit affirmed on all grounds.

Issue	Plaintiff's Argument (Rainey)	Defendant's Argument (Taylor)	Held
Denial of continuance	Trial should proceed; Taylor’s excuse unverified and conduct shows bad faith	Dental emergency and travel plans justified continuance	No abuse of discretion; judge reasonably found the dental excuse a ruse given evasion, Snapchat, and inconsistent evidence
Missing-witness instruction	Instruction appropriate because Taylor alone controlled his testimony	Instruction improper	Instruction proper; Taylor was peculiarly in control of producing himself
Admission of tour-bus video (Fed. R. Evid. 403)	Video highly probative of credibility and consciousness of guilt; admissible	Video unfairly prejudicial due to profanity and scuffle	Admissible; probative value substantial and not substantially outweighed by unfair prejudice
Verdict weight / compensatory remittitur	Verdict supported by testimony, video, corroboration, and damages evidence; deny remittitur	Verdict against the weight of evidence; damages unsupported or excessive	No miscarriage of justice; Illinois law governs remittitur and $1.13M falls within a reasonable range
Punitive damages (Due Process)	Punitive damages warranted by reprehensibility and conduct; ratio acceptable	$6M punitive excessive under Gore/State Farm guideposts	Punitive award upheld; conduct highly reprehensible and 6:1 ratio constitutionally permissible

Research Sys. Corp. v. IPSOS Publicité, 276 F.3d 914 (7th Cir. 2002) (continuance rulings reviewed for abuse of discretion)
United States v. Winbush, 580 F.3d 503 (7th Cir. 2009) (trial-scheduling and continuance deference)
Oxman v. WLS-TV, 12 F.3d 652 (7th Cir. 1993) (missing-witness instruction appropriate when witness is peculiarly within opponent’s power to produce)
Hoffman v. Caterpillar, Inc., 368 F.3d 709 (7th Cir. 2004) (district courts have broad discretion to give missing-witness instructions)
Davies v. Benbenek, 836 F.3d 887 (7th Cir. 2016) (deference to district court Rule 403 balancing unless no reasonable person could agree)
Gasperini v. Center for Humanities, Inc., 518 U.S. 415 (1996) (state law governs remittitur standards as substantive for Erie purposes)
State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (2003) (three guideposts for evaluating punitive damages under Due Process)
BMW of N. Am., Inc. v. Gore, 517 U.S. 559 (1996) (guideposts for punitive-damages review)
Mathias v. Accor Econ. Lodging, Inc., 347 F.3d 672 (7th Cir. 2003) (appellate review policing a range of punitive/compensatory ratios)
Gracia v. SigmaTron Int’l, Inc., 842 F.3d 1010 (7th Cir. 2016) (review of remittitur determinations for abuse of discretion)