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Casias v. State, Department of Corrections

United States District Court, D. New Mexico

July 2, 2019

ISAHA CASIAS, Plaintiff,
v.
STATE OF NEW MEXICO DEPARTMENT OF CORRECTIONS, TARACINA MORGAN and HERMAN GONZALES, Defendants.

          ORDER DENYING DEFENDANTS' MOTION FOR JUDGMENT AS A MATTER OF LAW AND MOTION TO ALTER OR AMEND THE JUDGMENT

          JOEL M. CARSON III, UNITED STATES CIRCUIT JUDGE

         This matter comes before the Court on Defendants' Motion for Judgment as a Matter of Law and Motion to Alter or Amend the Judgment (Doc. 226). Pursuant to Federal Rule of Civil Procedure (“Rule”) 50(b), Defendants move to vacate the judgment against them and enter judgment in their favor on the issue of deliberate indifference. Defendants also move to alter or amend the judgment with respect to Plaintiff's award of compensatory and punitive damages. Having reviewed the evidence and the relevant law, the Court denies Defendants' motions.

         I.

         Plaintiff Isaha Casias brought this civil rights lawsuit alleging state law negligence and Eighth Amendment constitutional violations under 42 U.S.C. § 1983 against the State of New Mexico Department of Corrections (“NMDC”) and two individual NMDC transport officers, Taracina Morgan and Herman Gonzales. On July 11, 2013, Morgan and Gonzales transported Plaintiff between prisons. During the transport, Morgan and Gonzales left the van unattended with the van's engine turned off, and the windows and doors closed. The heat caused Plaintiff to lose consciousness and convulse with uncontrollable muscle spasms. Plaintiff sought compensatory damages for pain and suffering. He also sought punitive damages against the individual defendants.

         In April 2019, the Court held a four-day jury trial. At the close of Plaintiff's case, Defendants moved for judgment as a matter of law (“JMOL”) pursuant to Rule 50(a) on the issues of negligence and deliberate indifference. The Court denied Defendants' motion. At the close of Defendants' case, Defendants again moved for JMOL on the same grounds. The Court again denied Defendants' motion.

         The jury returned a verdict in favor of Plaintiff. The jury specifically found that Plaintiff's confinement in the van on the date in question “posed a substantial risk of serious harm to his health and safety.” Doc. 221. The jury found that each defendant acted with deliberate indifference to that substantial risk of harm. Id. And the jury found that each defendant's acts or omissions caused Plaintiff to suffer damages. Id. The jury awarded Plaintiff $1, 000, 000 in compensatory damages against Defendants, jointly and severally, and $500, 000 in punitive damages against each individual defendant.

         On April 12, 2019, the Court entered Judgment on the Jury Verdict (“Judgment”) (Doc. 223). On May 9, 2019, Defendants renewed their motion for JMOL on the issue of deliberate indifference and filed a motion to alter or amend the judgment based on Plaintiff's damages award. Doc. 226.

         II.

         A motion for judgment as a matter of law may be made at any time before a case is submitted to a jury. Fed.R.Civ.P. 50(a). The party seeking JMOL must state specific grounds for its motion. Id. Where the pre-verdict motion was not granted, it may be renewed after trial by written motion within 28 days of the entry of judgment. Fed.R.Civ.P. 50(b). The renewed motion for JMOL is limited to those specific grounds raised in the Rule 50(a) motion. Marshall v. Columbia Lea Reg'l Hosp., 474 F.3d 733, 738-39 (10th Cir. 2007). When considering a renewed motion for JMOL following a jury verdict, a court may allow the judgment to stand, order a new trial, or direct entry of judgment as a matter of law. Unitherm Food Sys., Inc. v. Swift-Eckrich, Inc., 546 U.S. 394, 400 (2006) (quoting Fed.R.Civ.P. 50(b)).

         The burden on a party seeking judgment as a matter of law is high; JMOL “should be cautiously and sparingly granted.” Zuchel v. Denver, 997 F.2d 730, 734 (10th Cir. 1993) (quoting Black, Sivalls & Bryson, Inc. v. Keystone Steel Fabricating Inc., 584 F.2d 946, 951 (10th Cir. 1978)). The court “do[es] not weigh the evidence, pass on the credibility of the witnesses, or substitute [its] conclusions for that of the jury.” Harolds Stores, Inc. v. Dillard Dep't Stores, Inc., 82 F.3d 1533, 1546 (10th Cir. 1996). Rather, a party is entitled to JMOL “if the evidence points but one way and is susceptible to no reasonable inferences supporting the party opposing the motion.” Johnson v. Unified Gov't of Wyandotte Cnty., 371 F.3d 723, 728 (10th Cir. 2004) (quoting Brown v. Gray, 227 F.3d 1278, 1285 (10th Cir. 2000)).

         Defendants claim Plaintiff presented insufficient evidence at trial to demonstrate that the individual defendants had the requisite subjective intent for Eighth Amendment liability. The Court disagrees. The evidence supports the jury's finding that the individual defendants were deliberately indifferent to a substantial risk of serious harm to Plaintiff.

         Under the Eighth Amendment, prison officials are required to provide inmates humane conditions of confinement. Farmer v. Brennan, 511 U.S. 825, 832 (1994). This includes taking “reasonable measures to guarantee the safety of the inmates.” Id.; Lopez v. LeMaster, 172 F.3d 756, 759 (10th Cir. 1999). But that does not mean that every injury suffered by a prisoner leads to constitutional liability for the prison official tasked with maintaining the prisoner's safety. Rather, constitutional liability arises when both an objective and subjective standard are met. Farmer, 511 U.S. at 832. First, there must be an objectively serious deprivation, such as conditions posing a substantial risk of serious harm. Id. Second, the subjective standard requires that the prison officials were deliberately indifferent to that harm. Id.

         When describing the bounds of the deliberate indifference inquiry, the Supreme Court explained:

a prison official cannot be found liable under the Eighth Amendment for denying an inmate humane conditions of confinement unless the official knows of and disregards an excessive risk to inmate health or safety; the official must both be aware of facts from which the inference could be drawn that a ...

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