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Castillon v. Correction Corporation of America Inc.

United States District Court, D. Idaho

October 6, 2017

OMAR CASTILLON, DUSTY KNIGHT, JUSTIN PETERSON, LEON RUSSELL, CHRISTOPHER JORDAN, JACOB JUDD, MICHAEL FORD-BRIDGES and RAYMOND BRYANT, Plaintiffs,
v.
CORRECTIONS CORPORATION OF AMERICA, INC, Defendant.

          MEMORANDUM DECISION AND ORDER

          Dee Benson United States District Judge

         Before the Court are two post-trial motions: (1) Plaintiffs' Motion to Alter, Amend or Correct Judgment and/or for a New Trial [Dkt. 361]; and Defendant's Motion to Amend, Correct or Alter Judgment [Dkt. 362]. Both motions have been fully briefed and a hearing was held before the Court in Boise, Idaho on September 29, 2017. At the hearing, Plaintiffs were represented by Anthony Shallot and Nikld Ramirez-Smith. Defendant was represented by Daniel P. Struck and Kirtland G. Naylor. Having considered the written and oral arguments of the parties, along with the relevant facts and the law, the Court enters the following Order.

         BACKGROUND

         This case arouse out of an inmate-on-inmate assault that occurred on May 5, 2012 at the former Idaho Correctional Center, a private prison which, at the time of the attack, was operated by Defendant Corrections Corporation of America ("CCA") under contract with the Idaho Department of Corrections. On May 4, 2012, inmate Campos was assigned janitorial duties in the F-l Pod, the housing unit in which Plaintiffs and others were housed. While completing his assignment, he secretly rigged the janitorial closet so that it would not lock. The next day, a group of inmates who were returning to their cells after recreation time outside, hid in the closet and waited for the next group of prisoners to be released from their cells for their recreation time. A few minutes later, as the second group left their cells, the first group emerged from the closet and attacked the second group of inmates, some with shanks or other homemade weapons. The injured members of the second group are the plaintiffs in this case.

         Plaintiffs brought a Monell claim pursuant to 42 U.S.C. § 1983 against CCA, alleging a violation of their Eighth Amendment rights. [Dkt. 14]. See Monell v. New York City, 436 U.S. 658 (1978). In order to establish liability for a Monell claim under § 1983, a plaintiff must show a direct causal link between a policy or custom and the alleged constitutional deprivation. Mendiola-Marinez, 836 F.3d at 1247 (citing Castro v. County of Los Angeles, 833 F.3d 1060, 1075 (9th Cir. 2016)(quoting City of Canton v. Harris, 489 U.S. 378, 385 (1989)). Plaintiffs' claim was originally based on two theories: (1) CCA had a custom and policy of clustering gang members together, which created an environment that permitted the assault to occur; and (2) CCA had a custom and policy of understaffing that hindered the facility's ability to prevent or stop inmate-on-inmate violence. Judge Lodge of this Court granted summary judgment for CCA on Plaintiffs' "gang clustering" theory. He denied CCA's motion for summary judgment on Plaintiffs' overstaffing theory, however, finding "there is sufficient evidence to withstand summary judgment on Plaintiffs' claim that understaffing on May 4, 2012 was the moving force behind the attack." [Dkt. 236 at p. 30]. Judge Lodge found that "[a]bsent Offender Campos' closet rigging on May 4, 2012, a reasonable juror could conclude the assailants would not have been able to attack Plaintiffs on the morning of May 5, 2012." [Dkt. 236]. This was the issue presented to a jury at trial.

         In order to succeed on their claim at trial, Plaintiffs were required to show: (1) that their constitutional rights were violated; (2) that CCA had a custom and policy of understaffing; and (3) a direct causal link between the custom and policy of understaffing and the alleged constitutional deprivation. Mendiola-Martinez, 836 F.3d at 1247. See Fortson v. Los Angeles City Attorney's office, 852 F.3d 1190, 1195 (9th Cir. 2017). Under Monell, a plaintiff must show that "the policy at issue was the 'actionable cause' of the constitutional violation, which requires showing both 'but for' and proximate causation." Tsao v. Desert Palace, Inc., 698 F.3d 1128, 1146 (9th Cir. 2012).

         On February 22, 2017, following an eight day trial, the jury returned the Special Verdict Form finding that Plaintiffs proved the first two Monell elements, specifically, that Plaintiffs suffered a deprivation of their constitutional rights, and that CCA had a pattern and practice of understaffing. The jury decided however, that the Plaintiffs had not met their burden of proving that understaffing on May 4 and 5, 2012 was the cause of this incident. Accordingly, the jury declined to award Plaintiffs any actual, nominal or punitive damages. The Court entered Judgment in this case reflecting the jury's findings on the Special Verdict Form. [Dkt. 342].

         ANALYSIS

         I. Plaintiffs' Motion to Alter, Amend or Correct Judgment and/or for a New Trial rDkt. 3611

         Plaintiffs' motion seeks, alternatively, a new trial; a partial new trial on damages; or to have the judgment altered to enter judgment in favor of Plaintiffs and to include an award of nominal damages.

         A. Motion for a new trial

         "A new trial may be granted ... 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." Federal Rule of Civil Procedure 59(a)(1). Plaintiffs assert they are entitled to a new trial based on: (1) Jury Instruction Nos. 16 and 17; (2) the Special Verdict Form; and (3) specific evidentiaiy rulings.

         1. Jury Instructions

         Plaintiffs argue that they are entitled to a new trial because Jury Instruction Nos. 16 and 17 required the jury to find that understaffing on May 4 and 5 was the moving force of the injuries sustained. They assert in their motion that proof of a pattern or practice of understaffing during the ...


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