A Rikers Island inmate who claims he was beaten up by the correction officers is getting a new trial because the trial court prevented the jury from viewing evidence that was critical to his case.
The case is Rentas v. City of New York, decided on March 8. Rentas says that officers at Rikers Island beat the hell out of him and fabricated evidence against him, leading to his prosecution and prolonged detention at Rikers. He also sued them for malicous prosecution, but that claim got dismissed pre-trial. The jury instead heard evidence about the excessive use of force and fabricated evidence. At trial, the judge allowed the jury to see some but not all of the officers' reports about the incident; it was those reports that Rentas claimed supported his fabrication-of-evidence claims. Rentas also brought his Intentional Infliction of Emotional Distress claims to trial. The jury liked that claim and awarded him $67,000. While the jury also found in Rentas's favor on the excessive force and fabrication claims, it only gave him nominal damages on those claims.
The Court of Appeals (Parker, Lohier and Carney) issues a slew of rulings. First, on the malicious prosecution claim that got dismissed prior to trial, the Court of Appeals says the trial court got it wrong in finding that plaintiff could not show the charges that the officers filed against him in connection with his altercation with the officers lacked probable cause, an essential element of any malicious prosecution claim. While defendants said probable cause arose from the testimony of other inmates, those statements were merely quoted in an investigation report prepared by one of the defendants, and it is not clear these statements were independent and untainted information which prosecutors could rely in charging plaintiff with assault. In addition, plaintiff testified that the charges against him were false, and other evidence -- like photos which did not show that he suffered the injuries that would have existed had he attacked the officers -- further showed the charges against him lacked probable cause.
The "fair trial" claim arising from the officers' fabricated reports against plaintiff went to trial. Rentas won on this claim, but the jury gave him only nominal damages. The trial court allowed the jury to see some but not all the officers' reports. That was wrong, the appellate court says. While the City argues the reports were cumulative of other testimony, that misses the point. The reports themselves were a central part of Rentas's claim that the officers had falsified the reports. The reports also supported his excessive force claims. Even the jury wanted to see the reports during deliberations, to no avail. Rentas gets a new trial on his federal claims.
Rentas did spend three years in jail awaiting trial on his criminal charges which were dismissed, leading to his malicious prosecution claim. He wants the Court of Appeals to tell the trial court that it must allow the jury to award him compensatory damages for this, not nominal damages, which typically amount to a dollar. The Court of Appeals finds that nominal damages were permissible because the jury could have found that Rentas's detention was not caused by the fake evidence but "rather by whatever independent, untainted evidence supported probable cause." The jury found that some defendants fabricated evidence but that others did not. "The jury could have also found that the submission of the non-fabricated evidence would have resulted in Rentas's loss of liberty even in the absence of fabricated evidence." Were that the case, the jury could award only a dollar. On retrial, the jury will again be charged that they could give plaintiff compensatory damages or nominal damages.
Finally, the Court of Appeals says the jury was able to award plaintiff money on his state law IIED claim. Even assuming medical evidence is needed for this claim, plaintiff had that evidence in the form of hospital records showing anxiety, loss of sleep and PTSD. For those of you who want the big bucks in police misconduct cases, remember that this guy only got $67,000 for this.
Stephen Bergstein is a civil rights lawyer in Orange County, N.Y. He has briefed or argued more than 200 appeals in the state and federal courts.