Gregory v. State of Montana

District Court, D. Montana·Decided August 3, 2022·No. 4:20-cv-00051·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA GREAT FALLS DIVISION

CARRIE GREGORY,

CV-20-51-GF-BMM Plaintiff,

vs. ORDER RE: ATTORNEY’S FEES STATE OF MONTANA, and PROBATION OFFICER TOMEKA WILLIAMS,

Defendant.

INTRODUCTION Plaintiff Carrie Gregory (“Gregory”) has filed a Motion for Attorney’s Fees and Costs (Doc. 153). Plaintiff asks this Court to award $160,250 in attorney’s fees and $21,615 in costs, for a total of $181,865.47. (Id.) Gregory asks for this amount in addition to the jury’s award of $75,000, for a total judgment of $256,865.47 against the State of Montana (“the State”) and Probation Officer Tomeka Williams (“Williams”) (collectively, “Defendants”). (Id.) Williams has filed a Motion for Offset of Settlement Paid by Joint Tortfeasor (Doc. 165). Williams moves for a pro tanto offset of the judgment against her in the amount of the settlement paid by the City of Great Falls and Officer Scott Fisher. Id. The Court held a hearing on the matter on June 23, 2022. (Doc. 189).

BACKGROUND This case arises from the events that took place in the Montana Probation and Parole parking lot in Great Falls, Montana on May 15, 2020. (Doc. 154 at 2). Gregory had brought her son, Daniel, to the Probation and Parole office for officers

to arrest him. (Id.) Williams approached Gregory and forced her onto the hood of a car while officers were arresting Daniel. (Id.) Gregory claimed that she suffered injuries to her wrist and elbow from this encounter. (Id.) Great Falls Police Officer

Scott Fisher then forced Gregory to his police cruiser, where Gregory alleged that Officer Fisher’s aggressive move injured her knee. (Id.) The City of Great Falls initially charged Gregory with misdemeanor obstruction. (Id.) Surveillance cameras captured the events in the parking lot. (Id.) The

Montana Probation and Parole office failed to save the original footage even after Gregory’s attorneys demanded that Montana Probation and Parole save the video. (Id.) Deputy Chief Wayne Bye recorded the video on his cell phone before the

video was automatically erased from the system as part of a periodic erasure of the system. (Id.) The City of Great Falls dropped the charges against Gregory. (Id.) The Court issued an Amended Order Regarding Sanctions (Doc. 110) (“Sanctions Order”) stemming from the spoliation of the video footage. The Court imposed the following sanctions against the State: Williams used unreasonable force in the seizure of Gregory; testimony about the original video’s contents was

not permitted; the jury was to decide issues of causation, injury, and damages; the jury was to decide whether Williams acted with actual malice; and the Court would not allow the parties to present evidence of Deputy Chief Wayne Bye’s cell phone

recording. (Doc. 110 at 17). The City of Great Falls and Officer Fisher settled with Gregory for $35,000 before trial. (Doc. 168 at 3). The Court eventually allowed the cellular telephone recording of the footage to be presented to the jury at trial after the State’s witness

made several references to the video during her testimony despite the Court’s admonishment to the State’s counsel before the witness testified. The Court instructed the jury to consider only the conduct of Williams in their deliberations.

See generally (Doc. 143). The jury awarded Gregory $75,000 at trial for her claim against Williams for use of excessive force under 42 U.S.C. § 1983. (Doc. 145). The jury found in favor of Williams on Gregory’s negligent infliction of emotional distress claim. (Id.) The

jury awarded Gregory no punitive damages. (Id.) ANALYSIS I. Gregory’s Motion for Attorney’s Fees (Doc. 153) Gregory asks this Court to award $160,250 in attorney’s fees and $21,615.47

in costs, for a total of $181,865.47. (Doc. 154). Pursuant to the Civil Rights Attorney’s Fees Award of 1976, a court, in its discretion, may allow a party prevailing on a claim under 42 U.S.C. § 1983 to recover “reasonable attorney’s

fees as part of the costs.” 42 U.S.C. § 1988(b). A court retains “narrow” discretion to deny fees under § 1988. Mendez v. County of San Bernadino, 540 F.3d 1109, 1126 (9th Cir. 2009), overruled on other grounds by Arizona v. ASARCO LLC, 773

F.3d 1050 (9th Cir. 2014). Fee awards exist as the rule rather than the exception. Id. Whether Gregory succeeded on the merits The Court first must address Williams’s argument that Gregory retains no

right to recover attorney’s fees as she failed to succeed on the merits of her claims. (Doc. 167 at 5-8). Williams asserts that Gregory cannot obtain attorney’s fees as she cannot first establish that she was the “prevailing party.” (Id. at 6); Hensley v. Eckerhart, 461 U.S. 424, 433 (1983). Williams argues that the jury’s verdict in this

case arose directly from the Court’s Sanctions Order that penalized Defendants for failing to save the video footage of the events on May 15, 2021. (Doc. 167 at 6-8). Section 1988 of Title 42 allows a prevailing party to recover reasonable attorney’s fees in a § 1983 action. 42 U.S.C. § 1988(b). A court may consider

plaintiffs as the “prevailing party” for the purposes of attorney’s fees if they “succeed on any significant issue in litigation which achieves some of the benefit the parties sought in bringing suit.” Hensley, 461. U.S. at 433, (citing Nadeau v.

Helgemoe, 581 F.2d 275, 278-79 (1st Cir. 1978)). A plaintiff ordinarily would not be entitled to fees if they prevail based solely on a procedural or evidentiary ruling. Mantolete v. Bolger, 791 F.2d 784, 786 (9th Cir. 1986) (citing Hanrahan v. Hampton, 446 U.S. 754, 759 (1980). A plaintiff must establish entitlement to

“some relief on the merits of [her] claims.” Id. (quoting Hanrahan, 446 U.S. at 757). A determination of “the substantial rights of the parties” must have been rendered. Id. Where a plaintiff’s success on the legal claim stands as purely

technical or de minimis, a court may decline to conclude plaintiff has maintained status as the “prevailing party.” Tex. State Teachers Ass'n v. Garland Indep. Sch. Dist., 489 U.S. 782, 792-93 (1989). The Court’s Sanctions Order specified that Williams had used unreasonable

force in the seizure of Gregory, that testimony regarding the original contents of the video before spoliation was not allowed at trial, and that the parties were not allowed to present Deputy Chief Bye’s cell phone recording of the video to the

jury. (Doc. 110 at 17). Notably, the Court reserved to the jury issues of causation, injury, and damages. (Id.) The case stood the test of an extensive three-day trial. Gregory maintained the burden of proving her case without the benefit of the

original video.

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