Gratton v. United Parcel Service Inc

CourtDistrict Court, E.D. Washington
DecidedFebruary 12, 2025
Docket1:22-cv-03149
StatusUnknown

This text of Gratton v. United Parcel Service Inc (Gratton v. United Parcel Service Inc) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gratton v. United Parcel Service Inc, (E.D. Wash. 2025).

Opinion

1 2

3 4 5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 6

7 TAHVIO GRATTON, NO. 1:22-CV-3149-TOR 8 Plaintiff, ORDER GRANTING DEFENDANT’S 9 v. MOTION FOR NEW TRIAL

10 UNITED PARCEL SERVICE, INC.,

11 Defendant. 12

13 BEFORE THE COURT is Defendant’s Motion for New Trial, Amendment 14 of the Judgment, or Remittitur (ECF No. 271). This matter was submitted for 15 consideration with oral argument. The Court has reviewed the record and files 16 herein, considered the parties’ oral arguments, and is fully informed. For the 17 reasons discussed below, Defendant’s Motion for New Trial, Amendment of the 18 Judgment, or Remittitur (ECF No. 271) is GRANTED. 19 20 1 BACKGROUND 2 Between September 9‒12, 2024, this Court held a jury trial on Plaintiff’s

3 claims of violations of the Washington Law Against Discrimination (“WLAD”), 4 42 U.S.C. §1981, and wrongful termination while employed with Defendant at its 5 Yakima facility. At the conclusion of argument, the jury returned a verdict of

6 $39.6 million in compensatory damages. ECF No. 236. The Court provided an 7 extensive factual background of this matter in its Order Granting Judgment as a 8 Matter of Law pursuant to Federal Rule of Civil Procedure 50, where it vacated 9 punitive damages pursuant to 42 U.S.C. §1981(a). ECF No. 265. To the extent

10 that this Order relies on additional facts than those outlined in its prior Order, the 11 Court cites extensively to the record. Defendant now moves for either a new trial 12 or remittitur of the awarded emotional distress damages. ECF No. 271.

13 DISCUSSION 14 As a basis for its request, Defendant first points to an outsized jury verdict 15 not based on the clear weight of the evidence and cites Plaintiff’s counsel’s use of 16 previously excluded evidence as prejudicial and therefor the basis of the disparity.

17 ECF No. 271 at 18. Additionally, Defendant argues that a new trial is warranted 18 because the jury should have been further instructed on an affirmative defense 19 pursuant to the WLAD. Id. at 23. Alternatively, Defendant requests the Court

20 reopen a limited discovery for potential perjury discovered posttrial. Id. at 7‒9. 1 Federal Rule of Civil Procedure 59(A)(1)(a) governs a new trial may be 2 granted “for any reason,” in which a new trial had previously been granted in an

3 action at law in federal court. The Ninth Circuit has held that “[t]he trial court may 4 grant a new trial only if the verdict is contrary to the clear weight of the evidence, 5 is based upon false or perjurious evidence, or to prevent a miscarriage of justice.”

6 Passantino v. Johnson & Johnson Consumer Prods., 212 F.3d 493, 510 n.15 (9th 7 Cir. 2000); see also Montgomery Ward & Co. v. Duncan, 311 U.S. 243, 251 (1940) 8 (recognizing that historically new trials are granted on grounds such as “that the 9 verdict is against the weight of the evidence, that the damages are excessive, or

10 that, for other reasons, the trial was not fair to the party moving”). “Unlike with a 11 Rule 50 determination, the district court, in considering a Rule 59 motion for new 12 trial, is not required to view the trial evidence in the light most favorable to the

13 verdict.” Experience Hendrix L.L.C. v. Hendrixlicensing.com Ltd, 762 F.3d 829, 14 842 (9th Cir. 2014). In consideration of a Rule 59 motion, the district court must 15 weigh the evidence as the court viewed it during trial and set aside the verdict 16 where in the court’s “conscientious opinion, the verdict is contrary to the clear

17 weight of the evidence.” Murphy v. City of Long Beach, 914 F.2d 183, 187 (9th 18 Cir. 1990). 19 The Verdict Form in the present matter considered emotional damages under

20 the WLAD, 42 U.S.C. §1981, and wrongful termination in violation of public 1 policy holistically, all of which the jury found Plaintiff had proven. ECF No. 236. 2 A district court sitting in diversity jurisdiction applies the relevant state law for

3 measuring excessiveness. Cosby v. AutoZone, Inc., 445 Fed. Appx. 914, 916 (9th 4 Cir. 2011). In Washington, if the trial court, “find[s] the damages awarded by a 5 jury to be so excessive or inadequate as unmistakably to indicate that the amount

6 thereof must have been the result of passion or prejudice, the trial court may order 7 a new trial or may enter an order providing for a new trial unless the party 8 adversely affected shall consent to a reduction or increase of such verdict.” RCW 9 4.76.030. Washington courts hold that a jury award may be overturned if it

10 “shocks the conscience of the court” or if the award is outside the range of 11 substantial evidence in the record. Green v. McAllister, 103 Wn. App. 452, 462 12 (2000).

13 Further, a new trial is warranted where the “flavor of misconduct [] 14 sufficiently permeate[s] an entire proceeding to provide conviction that the jury 15 was influenced by passion and prejudice in reaching its verdict.” Kehr v. Smith 16 Barney, Harris Upham & Co., Inc., 736 F.2d 1283, 1286 (9th Cir. 1984) (quoting

17 Standard Oil Co. of California v. Perkins, 347 F.2d 379, 388 (9th Cir. 1965)). To 18 evaluate prejudice from attorney misconduct, courts in the Ninth Circuit consider 19 “the totality of circumstances,” which includes “the nature of the comments, their

20 frequency, their possible relevancy to the real issues before the jury, the manner in 1 which the parties and the court treated the comments, the strength of the case, and 2 verdict itself.” Hemmings v. Tidyman's Inc., 285 F.3d 1174, 1193 (9th Cir. 2002).

3 Remittitur, on the other hand, corrects jury awards that are excessive. 4 Pershing Park Villas Homeowners Assoc. v. United Pac. Ins. Co., 219 F.3d 895, 5 905 (9th Cir. 2000). When considering remittitur as a remedy for an excessive jury

6 award, a trial court must view evidence in the light most favorable to the 7 nonmoving party, Seymour v. Summa Vista Cinema, Inc., 809 F.2d 1385, 1387 (9th 8 Cir. 1987), and may not substitute its own judgment for that of the jury, D & S 9 Redi–Mix v. Sierra Redi–Mix & Contracting Co., 692 F.2d 1245, 1249 (9th Cir.

10 1982) (citations omitted). Instead, the court must review the evidence and reduce 11 the award according to the maximum amount substantiated by the proof. Redi– 12 Mix., 692 F.2d at 1249. “Generally, a jury's award of damages is entitled to great

13 deference and should be upheld unless it is ‘clearly not supported by the evidence’ 14 or ‘only based on speculation or guesswork.’” In re First All. Mortg. Co., 471 F.3d 15 977, 1001, 1003 (9th Cir.

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