Stampf v. Long Island Railroad
761 F.3d 192
| 2d Cir. | 2014Background
- Stampf and Trigg were LIRR locomotive engineers who briefly worked together; Trigg alleged Stampf grabbed her breast in July 2006, prompting an internal LIRR investigation and an MTA police filing.
- Trigg reported the incident to police; Stampf was arrested at work the night of July 9, 2006, and released on a DAT for forcible touching.
- A New York County DA declined to prosecute Stampf on December 27, 2006; no criminal complaint proceeded.
- The LIRR concluded Stampf violated the Anti-Harassment Policy and suspended her; an arbitration panel later reduced the suspension and awarded Stampf back pay.
- Stampf filed federal suit asserting multiple claims, including malicious prosecution; the district court granted summary judgment on most claims, and a jury found Trigg liable for malicious prosecution with a $480,000 award.
- This appeal challenges liability rulings, evidentiary rulings, and the damages award, including a remittitur option.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether DAT initiation supports malicious prosecution claim | Stampf contends DAT constitutes initiation of criminal action. | Trigg argues DAT does not initiate a criminal action. | DAT initiates a criminal prosecution for malicious prosecution purposes. |
| Whether termination in Stampf’s favor was proven | Declination constitutes favorable termination. | Declination without prejudice cannot show favorable termination. | Declination suffices to establish favorable termination. |
| Whether collateral estoppel barred Stampf's claim | Arbitration decision precludes claim. | Waived as a Rule 50 issue; not preserved. | Argument waived; not reviewable on appeal. |
| Admissibility of arbitration decision at trial | Arbitration decision is probative, relevant. | Arbitral process lacked sufficient fairness to admit. | District court did not abuse discretion in excluding arbitration decision. |
| Whether remittitur should adjust damages | Damages were within range of comparable cases. | Damages excessive and should be reduced. | Remittitur granted for past emotional distress and punitive damages; damages to be reduced to cap aggregate at $250,000 if Stampf accepts. |
Key Cases Cited
- Rosario v. Amalgamated Ladies’ Garment Cutters’ Union, Local 10, 605 F.2d 1228 (2d Cir. 1979) (DAT initiation can start a malicious prosecution action)
- Smith-Hunter v. Harvey, 95 N.Y.2d 191 (N.Y. Ct. App. 2000) (final termination requires more than nonpros; innocence not required)
- Verboys v. Town of Ramapo, 785 N.Y.S.2d 496 (2d Dep’t 2004) (dismissal without prejudice can be a favorable termination under certain facts)
- Snead v. Aegis Sec., Inc., 482 N.Y.S.2d 159 (4th Dep’t 1984) (DAT suffices to initiate criminal proceeding per Rosario lineage)
- Allen v. Town of Colonie, 583 N.Y.S.2d 24 (3d Dep’t 1992) (DAT initiation treated as initiation of criminal proceeding)
- McClellan v. New York City Transit Authority, 444 N.Y.S.2d 985 (Civ. Ct., Kings Co. 1981) (McClellan conflicted with Rosario on DAT as initiation)
- Rohman v. New York City Transit Auth., 215 F.3d 208 (2d Cir. 2000) (active role in prosecution can initiate malicious action)
- Manganiello v. City of New York, 612 F.3d 149 (2d Cir. 2010) (elements of malicious prosecution incl. initiation and lack of probable cause)
- Gasperini v. Center for Humanities, Inc., 518 U.S. 415 (1996) (standard for reviewing excessiveness of awards (Rule 59 remittitur))
- Payne v. Jones, 711 F.3d 85 (2d Cir. 2013) (framework for reviewing punitive damages under Gore)
- BMW of N. Am., Inc. v. Gore, 517 U.S. 559 (1996) (guideposts for punitive damages: reprehensibility, ratio, comparison to penalties)
- State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (2003) (ratio considerations for punitive damages)
- Patterson v. Balsamico, 440 F.3d 104 (2d Cir. 2006) (emotional distress damages; upper end of comparable awards)
- Lynch v. County of Nassau, 717 N.Y.S.2d 248 (2d Dep’t 2000) (reductions where awards exceed comparable cases)
- Strader v. Ashley, 877 N.Y.S.2d 747 (3d Dep’t 2009) (high compensatory awards in malicious prosecution cases across contexts)
- Morsette v. Final Call, 764 N.Y.S.2d 416 (1st Dep’t 2003) (judicial reductions in damages for emotional distress)