AELE LAW LIBRARY OF CASE SUMMARIES:
Civil Liability of Law Enforcement Agencies
& Personnel
Procedural: Separate Trials
322:147 Jury properly awarded $1 in nominal
damages and $20,000 in punitive damages (later reduced to $15,000) against
officer who allegedly used excessive force against arrestee during booking
process; trial court improperly dismissed claims against city following
trial of claims against individual officers, since plaintiff could pursue
city's liability even if he was barred from receiving anything more than
$1 in damages against municipality. Amato v. City of Saratoga Springs,
N.Y., #97-9623, 170 F.3d 311 (2nd Cir. 1999).
310:148 Trial court erred in bifurcating
trial on liability in excessive force lawsuit from trial on damages and
in excluding, from liability phase, evidence on severity of plaintiff's
alleged injuries; severity of plaintiff's injuries was relevant in determining
whether excessive force was used at all. Martin v. Heideman, 106 F.3d 1308
(6th Cir. 1997).
311:165 Separate trials were required in
claims against officers and city when evidence of officers' alleged past
misconduct would be admissible to prove claims against city, but inadmissible
in claims against officers. Daniels v. Loizzo, 178 F.R.D. 46 (S.D.N.Y.
1998).
280:53 Plaintiff's claims against police
officer and against county should be tried separately when evidence of
county's customs and policies, including past alleged incidents of police
misconduct, would be prejudicial to officer's defense Dawson v. Prince
George's County, 896 F.Supp. 537 (D.Md 1995). [Cross-references: Administrative
Liability: Training, Supervision; Dogs]
{N/R} Because of parties' agreement to bifurcate
trial of claims against individual officers and city, the trial court properly
refused to allow the plaintiff, during the trial of claims against the
officers, to try to present evidence of other alleged incidents of police
misconduct Watkins v. Schriver, 52 F.3d 769 (8th Cir. 1995).
Court orders separate trials of civil rights
claims against individual officers and claims against municipal entities,
since vindication of individuals might make trial of claims against city
unnecessary; individual offices were entitled to separate representation
from that provided to the city Ricciuti v. NY City Transit Authority, 796
F.Supp. 84 (S.D.N.Y. 1992).