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Styers v. Commonwealth

February 29, 2008

GREGORY STYERS, PLAINTIFF
v.
COMMONWEALTH OF PENNSYLVANIA, ET AL., DEFENDANTS



The opinion of the court was delivered by: William W. Caldwell United States District Judge

MEMORANDUM

I. Background

We are considering Defendant David Guido's post-trial motion for judgment as a matter of law and for a reduction of the jury's damages award. (doc. 62). Plaintiff Gregory Styers, a trooper with the Pennsylvania State Police ("PSP"), filed this lawsuit pursuant to 42 U.S.C. § 1983 alleging that Guido and other PSP employees retaliated against him for exercising his First Amendment rights. Styers alleged that Defendants did so in response to his successful pursuit of a grievance concerning a transfer within the PSP.

On August 8, 2007, a jury found Guido liable for retaliating against Styers for exercising his First Amendment rights. (doc. 53).*fn1 On August 28, 2007, we entered judgment against Guido and in favor of Styers reflecting the jury's verdict and its award of $0 in compensatory damages---which was converted to $1.00 in nominal damages--and $20,000.00 in punitive damages. (doc. 58). Guido has filed a motion for judgment as a matter of law and for reduction of the punitive damages award. (doc. 62). Styers filed a brief in opposition (doc. 74), and Guido did not file a brief in reply. Upon review of the motion and the record, we will deny Guido's motion.

II. Judgment as a Matter of Law

In his motion for judgment as a matter of law, Guido argues that Styers failed to show his personal involvement in the retaliatory conduct. (doc. 73, p. 4). We will grant judgment as a matter of law pursuant to Federal Rule of Civil Procedure 50 "only if, viewing the evidence in the light most favorable to the non-movant and giving [the non-movant] the advantage of every fair and reasonable inference, there is insufficient evidence from which a jury reasonably could find liability." Lightning Lube v. Witco Corp., 4 F.3d 1153, 1166 (3d Cir. 1993). Motions for judgment as a matter of law are granted sparingly, and we will sustain a verdict if the record contains the "minimum quantum of evidence from which a jury might reasonably afford relief." Parkway Garage, Inc. v. City of Philadelphia, 5 F.3d 685, 691 (3d Cir. 1993), abrogation on other grounds recognized by United Artists Theatre Circuit, Inc. v. Twp. of Warrington, Pa., 316 F.3d 392 (3d Cir. 2003).

Section 1983 claims require personal involvement by the defendant in the alleged wrongs. Baraka v. McGreevey, 481 F.3d 187, 210 (3d Cir. 2007). Personal involvement may take the form of direct participation. Rode v. Dellarciprete, 845 F.2d 1195, 1207 (3d Cir. 1988). Alternatively, a defendant may be personally involved through "allegations of personal direction or of actual knowledge and acquiescence." Id. Guido argues that the evidence does not show his personal involvement in any of the retaliatory acts supporting the verdict. The alleged retaliatory conduct that we instructed the jury to consider included the following: (1) Styers' allegation that Guido, as his supervisor, made it more difficult for him to qualify as a pilot-in-command of a PSP helicopter when he returned to the unit following his successful grievance, and (2) Styers' allegation that Guido authorized him to attend a court hearing in uniform only to later file a complaint which led to his discipline.

The evidence supports the jury's conclusions as to Guido's involvement in both instances of retaliatory conduct. With respect to Styers' qualification as a pilot, even though Guido did not set Styers' hourly certification requirement upon his return to the aviation unit, Guido did not have a plan in place to help Styers qualify and he did not assign Styers a "check pilot" so that he could complete the in-flight certification requirement. Notes from Trial ("NT"), 68-70. The jury, by crediting Styers' testimony, could conclude that Guido was personally involved in this retaliatory conduct.

As to the disciplinary action for attending the court hearing, Styers testified that he notified Guido of his scheduled court hearings and specifically asked Guido if he could wear his uniform on the day in question. NT, 70-75. After receiving authorization to attend the hearing in uniform, Styers testified that Guido observed him dress in a PSP uniform, went to the hearing, and, upon return, filed an internal affairs complaint. Id. Styers was disciplined as a result of the complaint. Id. at 103. Again, a jury, crediting Styers' testimony, could determine that Guido was personally involved in this retaliatory conduct. Accordingly, the record contains more than the minimum quantum of evidence of Guido's personal involvement to sustain the jury's verdict.

III. Reduction of the Punitive Damages Award

Guido also argues that the $20,000.00 punitive damages award is unconstitutionally excessive and unreasonable based upon the facts of the case. (doc. 73, p. 8). We will uphold the punitive damages award.

A. Constitutionality of the Damages Award

The Constitution provides due process protection from a "grossly excessive" punitive damage award because such an award "furthers no legitimate purpose and constitutes an arbitrary deprivation of property." State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408, 416-17, 123 S.Ct. 1513, 155 L.Ed.2d 585 (2003). In evaluating the reasonableness of a punitive damages award, courts consider three guideposts: "(1) the degree of reprehensibility of the defendant's misconduct; (2) the disparity between the actual or potential harm suffered by the plaintiff and the punitive damages award; and (3) the difference between the punitive damages awarded by the jury and the civil penalties authorized or imposed in comparable cases." Id. at 418 (citing BMW of N. Am. v. Gore, 517 U.S. 559, 574-75, 116 S.Ct. 1589, 134 L.Ed.2d 809 (1996)).

The degree of reprehensibility of the defendant's misconduct is the first and "most important indicium of the reasonableness of a punitive damages award." Id. at 419. We evaluate the reprehensibility of a defendant's misconduct by considering whether the harm caused was physical as opposed to economic; the tortious conduct evinced an indifference to or a reckless disregard of the health or safety of others; the target of the conduct had financial vulnerability; the conduct involved ...


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