Hardy v. City Of Selma

District Court, S.D. Alabama·Decided September 19, 2024·No. 2:21-cv-00522·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA NORTHERN DIVISION

SHARON HARDY, as personal ) representative of the estate of ) Jeffrey Hardy, et al., ) ) Plaintiffs, ) ) v. ) CIVIL ACT. NO. 2:21-cv-522-TFM-B ) CITY OF SELMA, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Pending before the Court are many post-trial motions: (1) Plaintiffs’ Motion for Equitable Relief: Reinstatement or Front Pay (Doc. 193, filed September 15, 2023); (2) Plaintiffs’ Amended Motion for Prejudgment Interest (Doc. 213, filed January 30, 2024); and (3) Plaintiffs’ Motion for Equitable Relief Annual Leave, Sick Leave and Retirement (Doc. 198, filed October 13, 2023). In the first post-trial motion, Plaintiffs motion the Court award them equitable relief in the form of reinstatement or, in the alternative, front pay. Doc. 193. Defendant City of Selma filed a response in opposition. Doc. 195. Having considered the motion, response, and relevant law, the motion is GRANTED in part and DENIED in part. In the second post-trial motion, Plaintiffs motion the Court award each prejudgment interest for the damage awards that were returned by the jury. Doc. 213. Defendant City of Selma filed a response in opposition. Doc. 216. Having considered the motion, response, and relevant law, the motion is GRANTED in part and DENIED in part. In the third post-trial motion, Plaintiffs motion the Court award them equitable relief for annual leave, sick leave, and retirement credit that they would have accrued had they not been placed on unpaid administrative leave by Defendant City of Selma. Doc. 198. Defendant City of Selma filed a response in opposition. Doc. 217. Having considered the motion, response, and relevant law, the motion is DENIED. I. PROCEDURAL BACKGROUND The procedural background of this matter was summarized in the Court’s June 9, 2023

Memorandum Opinion and Order then updated in the Court’s August 23, 2024 Memorandum Opinion and Order. Docs. 126, 221. Having resolved Defendant City of Selma’s (“Defendant” or “the City”) motion for judgment as a matter of law and Plaintiffs Jeffrey Hardy (“Hardy”), Toriano Neely (“Neely”), and Kendall Thomas (“Thomas”) (collectively, “Plaintiffs”) oral motion for judgment as a matter of law, the Court now turns its attention to the post-trial motions, which are ripe for review, and the Court finds oral argument unnecessary. II. DISCUSSION AND ANALYSIS A. Plaintiffs’ Motion for Equitable Relief: Reinstatement or Front Pay (Doc. 193)

Plaintiffs motion the Court award each equitable relief in the form of reinstatement or, in the alternative, front pay. Doc. 193. Plaintiffs also request the Court award them lost pension benefits or credit as part of any front pay award as well as in addition to the jury’s damages award, which encompassed the period when Plaintiffs were placed on unpaid administrative leave until the jury rendered its verdict. Id. at 6-7. In support of the motion, Plaintiffs argue the equitable relief that they request is warranted based on the scope of the jury’s verdict and the type of constitutional violations they alleged against the City. See id. at 1-8. In response, the City states, without conceding equitable relief is available to any of the plaintiffs, it agrees to reinstate Thomas subject to certain terms and suggests the Court should enter an order to that effect. Doc. 195 at 2-3. The suggested terms for Thomas’s reinstatement include: 1) Kendall Thomas will return to the Selma Police Department on a specific date as a police Sergeant at a salary of $50,581.44 per year, plus incentives;

2) Thomas’[s] return to work is subject to his being certified/recertified as required by the Alabama Peace Officers Standards and Training Commission (APOST);

3) Once Thomas is successfully certified/recertified through APOST, he will be provided training for the Lieutenant promotion test. Thomas will then be allowed to take the promotion test for Lieutenant.

Id. The City further states, since reinstatement is the presumptively preferred remedy in this case, the Court does not need to consider the issue of front pay as to Thomas. Id. at 3. The City argues, in any case, front pay is not warranted for Thomas since the jury found he failed to mitigate his damages when he did not heed the offers of the Selma Police Department (“SPD”) to return to duty, no proof was offered that showed the City’s conduct was egregious, and an award of front pay would be speculative. Id. As for Hardy and Neely, the City argues they are neither entitled to reinstatement nor front pay because the jury found they both were disabled and unable to return to work and applied for, and received, Social Security disability benefits. Id. at 3-4. Separate from the issues of reinstatement and front pay, the City argues the Court should not award lost pension benefits or credit for the period that is covered by the jury’s verdict because the issue was already decided by the jury. Id. at 6-7. Specifically, the City argues the jury was already instructed to consider Plaintiffs’ lost income and benefits if they found for Plaintiffs on any of their claims. Id.; see Doc. 208. It is a “well-settled principle that the nature and scope of the remedy are to be determined by the violation, which means simply that federal-court decrees must directly address and relate to the constitutional violation itself.” Milliken v. Bradley, 433 U.S. 267, 282, 97 S. Ct. 2749, 53 L. Ed. 2d 745 (1977). The leading case for damages in a procedural due process case is Carey v. Piphus, 435 U.S. 247, 98 S. Ct. 1042, 55 L. Ed. 2d 252 (1978). The Carey Court held that compensation for injuries emanating from the deprivation of a constitutional right “should be tailored to the interests protected by the particular right in question.” Id. at 259. The Carey Court went on to conclude that “compensatory damages for a procedural due process violation may not be awarded absent proof of actual injury. The Court further held, however, that even in the absence of such proof, ‘the denial of procedural due process should be actionable for nominal damages.’” Franklin v. Aycock, 795 F.2d 1253, 1263 (6th Cir. 1986) (quoting Carey, 435 U.S. at 266)). Carey, however, did not reach the particular issue of equitable relief.

It is within the sound discretion of a district court whether to award equitable relief. Goldstein v. Manhattan Indus., Inc., 758 F.2d 1435, 1448 (11th Cir. 1985). A court decides “the propriety of equitable relief based on the facts as found by the jury.” Haskins v. Boaz, 822 F.2d 1014, 1015 (11th Cir. 1987) (citation omitted) (emphasis in original).

. . . [T]he pertinent inquiry in determining the proper scope of damages in the context of a procedural due process violation is whether the deprivation is justified. See, e.g., Harden v. Pataki, 320 F.3d 1289, 1300 (11th Cir. 2003) (reasoning that a justifiable injury a habeas petitioner may sustain is not properly compensable under 42 U.S.C. § 1983); Cnty. of Monroe v. United States Dep’t of Labor, 690 F.2d 1359, 1363 (11th Cir. 1982) (concluding that “injury caused by justified termination is not compensable in the form of back pay”).

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