Banks v. Ashford 1369 Hospitality LLC

District Court, D. Puerto Rico·Decided March 14, 2025·No. 3:23-cv-01055·Unknown

Opinion

MICHELE F. BANKS, et al., Plaintiffs,

v. Civil No. 23-1055 (BJM)

ASHFORD 1369 HOSPITALITY LLC, et al., Defendants.

ORDER After a three-day jury trial, the jury found Ashford 1369 Hospitality LLC and Universal Insurance Company (collectively, “Defendants”) liable for negligent maintenance on the premises of the AC Hotel in Condado, San Juan, which caused plaintiff Michele Banks to slip and fall on the afternoon of June 11, 2021. Dkt. 111. The jury awarded $1,800,000 to Ms. Banks and $150,000 to her husband, co-plaintiff Andre Banks (collectively, “Plaintiffs”). Id. at 3. The jury also found that Ms. Banks’s own actions or omissions did not contribute to her fall, and that Defendants were fully responsible for causing her injuries. Id. Before the court is Defendants’ post-trial motion for a new trial and/or for remittitur pursuant to Fed. R. Civ. P. 59. Dkt. 119. Defendants seek a new trial under the theory that evidentiary issues and misrepresentations at trial justify vacating the jury verdict. Id. at 7-22. Alternatively, they seek remittitur, claiming that the jury’s damages award is unsupported by the evidence. Id. at 22-24. Plaintiffs opposed. Dkt. 122. This case is before me with the consent of the parties. Dkt. 18. STANDARD OF REVIEW Federal Rule of Civil Procedure 59 states that “[t]he court may, on motion, grant a new trial on all or some of the issues—and to any party— . . . after a jury trial, for any reason for which a new trial has heretofore been granted in an action at law in federal court[.]” Fed. R. Civ. P. 59(a)(1). “[A] district court is free to independently weigh the evidence” when deciding whether to grant a new trial. Jennings v. Jones, 587 F.3d 430, 436 (1st Cir. 2009). That said, “a district judge cannot displace a jury’s verdict merely because he disagrees with it or because a contrary verdict may have been equally supportable.” Id. (citing Ahern v. Scholz, 85 F.3d 774, 780 (1st Cir. 1996) (internal quotation marks omitted). “[A] jury’s verdict on the facts should only be overturned

in the most compelling circumstances.” Wells Real Estate, Inc. v. Greater Lowell Bd. of Realtors, 850 F.2d 803, 811 (1st Cir. 1988). Further, when a party argues for a new trial based on alleged errors that were not raised or objected to during trial, such alleged errors are reviewed under the deferential “plain error” standard. See Aguayo v. Rodríguez, Civil No. 14-1059 (MEL), 2016 U.S. Dist. LEXIS 81882, at *9-10 (D.P.R. June 21, 2016) (“If an argument is not objected to in a timely manner, the claims are forfeited and will be reviewed only for plain error”) (citing Smith v. Kmart Corp., 177 F.3d 19, 25-26 (1st Cir. 1999)). “Under plain error review, we will consider a forfeited objection only if: (1) an error was committed; (2) the error was “plain” (i.e. obvious and clear under current law); (3) the error was prejudicial (i.e. affected substantial rights); and (4) review is needed to prevent a

miscarriage of justice.” Smith, 177 F.3d at 25-26. Prejudice under the third prong requires “a reasonable probability that, but for the alleged error, the verdict would have been different.” Burnett v. Ocean Props., 987 F.3d 57, 71 (1st Cir. 2021) (citing Teixeira v. Town of Coventry ex rel. Przybyla, 882 F.3d 13, 19 (1st Cir. 2018)). “Plain error is a rare species in civil litigation, encompassing only those errors that reach the pinnacle of fault . . . .” Smith, 177 F.3d at 26. (internal citation omitted). “To merit reversal, the error must have resulted in a miscarriage of justice or seriously affected the fairness, integrity or public reputation of the judicial proceedings.” Id. Alternatively, a party may seek remittitur of a jury verdict pursuant to Fed. R. Civ. P. 59(e). “A party seeking remittitur bears a heavy burden of showing that an award is grossly excessive, inordinate, shocking to the conscience of the court, or so high that it would be a denial of justice to permit it to stand.” Rivera v. Turabo Med. Ctr. P’ship, 415 F.3d 162, 173 (1st Cir. 2005) (quoting

Currier v. United Techs. Corp., 393 F.3d 246, 256 (1st Cir. 2004)). “In reviewing an award of damages, the district court is obliged to review the evidence in the light most favorable to the prevailing party and to grant remittitur or a new trial on damages only when the award exceeds any rational appraisal or estimate of the damages that could be based upon the evidence before it.” Wortley v. Camplin, 333 F.3d 284, 297 (1st Cir. 2003) (internal quotation marks and citation omitted). “The First Circuit adheres to the maximum recovery rule, which allows the Court to direct a remittitur geared to the maximum recovery for which there is evidentiary support, subject to Plaintiff’s right to reject the remittitur and instead proceed with a new trial on the disputed damages claim.” Correa-Carrillo, 594 F. Supp. 3d at 429-430 (quoting Trainor v. HEI Hosp., LLC, 699 F.3d 19, 33 (1st Cir. 2012) (internal quotation marks omitted)).

DISCUSSION Defendants advance several arguments in favor of vacating the jury verdict and holding a new trial: (1) Plaintiffs failed to timely disclose Ms. Banks’s medical records containing evidence of an intervening injury; (2) Ms. Banks’s W-2 forms were improperly admitted into evidence; (3) Ms. Banks’s testimony concerning her transportation expenses was improper; (4) Ms. Banks’s testimony concerning her medical expenses and interest on those expenses was improper; and (5) Plaintiffs’ counsel made improper statements during his closing arguments. Alternatively, Defendants seek remittitur of the damages award. I will address each argument below. A. Disclosure of Medical Records Defendants first argue that the jury verdict was marred by the improper disclosure and admission of Michele Banks’s medical records. Their main contention is that Plaintiffs failed to disclose Ms. Banks’s full medical records until the eve of trial.1 Defendants claim that this was

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