The opinion of the court was delivered by: Terrence F. McVerry United States District Court Judge
MEMORANDUM OPINION AND ORDER OF COURT
Before the Court for consideration and disposition are the following post-trial motions: the RULE 50 MOTION OF DEFENDANTS, UNIVERSAL DEVELOPMENT MANAGEMENT, INC., T/D/B/A THE MEADOWS APARTMENTS, UDE OF MITCHELL ROAD, LTD., AND SHERRI LYNN WILSON ("Rule 50 Motion") (Document No. 136) and the RULE 59 MOTION OF DEFENDANTS, UNIVERSAL DEVELOPMENT MANAGEMENT, INC., T/D/B/A THE MEADOWS APARTMENTS, UDE OF MITCHELL ROAD, LTD., AND SHERRI LYNN WILSON ("Rule 59(e) Motion") (Document No. 137). The issues have been fully briefed. See Document Nos. 148, 149, 151, 158-60, & 166.
This action arises out of events which occurred on September 11, 2001. The basic facts of the case are as follows: Plaintiff is a radiologist of Arabic descent and, at the relevant time, was a resident of The Meadows Apartments ("The Meadows"). Defendant Sherri Lynn Wilson ("Wilson") was the resident manager of The Meadows. After the terrorist attacks occurred, Wilson, with the assistance of The Meadows' maintenance man, entered Plaintiff's apartment and looked around at the contents and condition thereof. Wilson reported to the local police that the items and conditions that she found in the apartment were suspect and possibly indicative of terrorist activity. For example, Wilson reported that she found a white powder on counter tops in the apartment. The white powder turned out to be dust. She also told the police that she saw a flying manual for a commercial jet airplane and a computer disc jacket which depicted an airplane exploding in midair. The "flying manual" was an instruction for a computer game, and the computer disc jacket, which also related to a computer game, actually depicted a plane flying into the sunset. Plaintiff introduced considerable evidence at trial from which the jury could have believed that Wilson either grossly exaggerated or simply lied about the existence and/or character of the items that she saw in his apartment. The Federal Bureau of Investigation ("FBI") quickly became involved in an investigation of Plaintiff and obtained a search warrant for his apartment, which was immediately executed. See Document No. 22.
At the time of the terrorist attacks, Plaintiff was working as a radiologist on assignment in New Mexico on a "locum tenens" basis. The FBI located and detained Plaintiff in New Mexico and questioned him regarding his knowledge of and involvement in the terrorist attacks. The matter received considerable publicity in the local and national media after September 11, 2001. Plaintiff was also subpoenaed to testify before a federal grand jury empaneled in the Western District of Pennsylvania, but the FBI investigation of Plaintiff was discontinued before his grand jury appearance was scheduled to take place. Plaintiff was never charged with a criminal offense, and the FBI investigation ultimately concluded that he had no connection whatsoever to the terrorist activity. All of the items found by the FBI in Plaintiff's apartment were lawful to possess and had some innocent explanation. Nevertheless, Plaintiff was terminated from his position in New Mexico. Additionally, Defendants declined to renew Plaintiff's month-to-month lease at The Meadows Apartments, and he was forced to relocate.
Plaintiff filed a Complaint which alleged violations of 42 U.S.C. § 1981 and the Fair Housing Act, as well as state law claims for trespass and invasion of privacy.*fn1 A jury trial commenced on September 12, 2005. Plaintiff rested on September 15, 2005. Defendants then made an oral motion for judgment as a matter of law pursuant to Rule 50(a) of the Federal Rules of Civil Procedure. The Court heard the parties' arguments and denied the motion on the record.
Defendants then presented additional evidence and rested. Defense counsel thereafter renewed the motion for judgment as a matter of law "for the reasons previously stated," which the Court denied summarily.*fn2 See Reply in Supp. of Def's Rule 50 Motion at unnumbered 3.
The jury heard closing arguments and was charged on September 16, 2005. On September 22, 2005, the jury found Defendants liable for invasion of privacy, but not liable as to the alleged violations of 42 U.S.C. § 1981, the Fair Housing Act, and trespass. Document No. 129. The jury awarded Plaintiff compensatory damages of $850,000 and punitive damages of $1,600,000, for a total award of $2,450,000. The Court entered judgment on the verdict, and Defendants timely filed the instant motions.
A motion for judgment as a matter of law is governed by Rule 50 of the Federal Rules of Civil Procedure, which provides in relevant part:
(a) Judgment as a Matter of Law.
(1) If during a trial by jury a party has been fully heard on an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find for that party on that issue, the court may determine the issue against that party and may grant a motion for judgment as a matter of law . . . .
(b) Renewing Motion for Judgment After Trial; Alternative Motion for New Trial. If, for any reason, the court does not grant a motion for judgment as a matter of law made at the close of all the evidence, the court is considered to have submitted the action to the jury subject to the court's later deciding the legal questions raised by the motion. The movant may renew its request for judgment as a matter of law by filing a motion no later than 10 days after entry of judgment. . . . In ruling on a renewed motion, the court may:
(1) if the verdict was returned:
(A) allow the judgment to stand,
(B) order a new trial, or
(C) direct entry of judgment as a matter of law; . . . . Fed. R. Civ. P. 50(a)(1) and (b).
A Rule 50 motion should be granted only if "viewing the evidence in the light most favorable to the non-movant and giving it the advantage of every fair and reasonable inference, there is insufficient evidence from which a jury could reasonably find liability." Gagliardo v. Connaught Laboratories, Inc., 311 F.3d 565, 568 (3d Cir. 2002) (citation omitted). Judgment as a matter of law pursuant to Rule 50(b) is proper when the evidence and its inferences, considered as a whole and viewed in the light most favorable to the nonmoving party, can support only one reasonable conclusion-- that the moving party is entitled to judgment notwithstanding the adverse verdict. Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150-51 (2000). Although judgment as a matter of law should be granted sparingly, "federal courts do not follow the rule that a scintilla of evidence is enough. The question is not whether there is literally no evidence supporting the party against whom the motion is directed but whether there is evidence upon which the jury could properly find a verdict for that party." Patzig v. O'Neil, 577 F.2d 841, 846 (3d Cir. 1978). "A jury verdict can be displaced by judgment as a matter of law only if the record is critically deficient of the minimum quantum of evidence from which the jury might reasonably afford relief." Wilson v. Philadelphia Detention Center, 986 F. Supp. 282, 286 (E.D. Pa. 1997) (quotations and internal quotation marks omitted).
In the alternative, Defendants contend in their Rule 59(e) Motion that the Court should order a new trial, vacate the punitive damages award or grant a remittitur of a portion of the punitive damages award. Pursuant to Rule 59 of the Federal Rules of Civil Procedure:
A new trial may be granted to all or any of the parties and on all or part of the issues . . . in an action in which there has been a trial by jury, for any of the reasons for which new trials have heretofore been granted in actions at law in the courts of the United States . . . .
The standard for granting a new trial is less rigorous than the standard for granting judgment as a matter of law and the court may grant a new trial even when it finds that a judgment as a matter of law is not an appropriate remedy. Roebuck v. Drexel University, 852 F.2d 715, 735 (3d Cir. 1988). A motion for a new trial may be sought on the grounds that the verdict is against the weight of the evidence, that the damages are excessive, or that the district court made substantial errors in the admission or rejection of evidence or in its instructions to the jury. See Montgomery Ward & Co. v. Duncan, 311 U.S. 243, 251 (1940). Generally, the decision whether or not to grant a new trial "is committed to the sound discretion of the district court." Bonjorno v. Kaiser Aluminum & Chem. Corp., 752 F.2d 802, 812 (3d Cir. 1984). The district court's latitude varies, however, depending upon the type of error alleged. Klein v. Hollings, 992 F.2d 1285, 1289-90 (3d Cir. 1993). Its latitude "is broad when the reason for interfering with the jury verdict is a ruling on a matter that initially rested within the discretion of the court," such as evidentiary rulings. Id. The district court's discretion is more limited, however, when the type of error alleged is that the jury's verdict is against the weight of the evidence. In such a situation, a new trial should be awarded "only when the record shows that the jury's verdict resulted in a miscarriage of justice or when the verdict, on the record, cries out to be overturned or shocks ...