Knight v. Metropolitan Government

136 F. App'x 755
CourtCourt of Appeals for the Sixth Circuit
DecidedApril 4, 2005
Docket03-6520
StatusUnpublished
Cited by10 cases

This text of 136 F. App'x 755 (Knight v. Metropolitan Government) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Knight v. Metropolitan Government, 136 F. App'x 755 (6th Cir. 2005).

Opinion

OPINION

GILMAN, Circuit Judge.

In 1975, Jimmie D. Knight, a police officer with the Metropolitan Nashville Police Department (Metro), was injured on the job. Following years of intermittent work thereafter with Metro and other entities, Knight’s physician finally cleared him to return to the police force in 1999 with no restrictions. Knight informed Metro of his desire to return to work at that time, but he was never rehired for reasons disputed by the parties. He brought suit against Metro under the Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12101-12213, alleging that Metro’s refusal to allow him to return to the force was part of a department-wide unofficial policy of not rehiring disability pensioners. A jury delivered a verdict in Knight’s favor and awarded him $150,000 in compensatory damages. Metro moved (1) to alter or amend the judgment, (2) for judgment as a matter of law, and (3) for a new trial. All three motions were denied by the district court.

On appeal, Metro argues that the district court erred in not granting Metro’s motion for judgment as a matter of law. It also contends that, in the alternative, Metro should have received a new trial or a remittitur because the jury verdict was excessive and against the weight of the evidence. Finally, Metro claims that the district court erred in allowing the jury to consider prejudicial testimony that should have been excluded as inadmissible hearsay. For the reasons set forth below, we AFFIRM the judgment of the district court.

I. BACKGROUND

In 1975, Knight, a Metro police officer, injured his back and neck in a motorcycle accident that occurred while he was on duty. His injuries required him to be placed on disability status in 1979. From 1979 to 1986, he worked for Metro intermittently as his injuries allowed. He received a disability pension when he was not working. Knight began taking on other part-time jobs starting in 1986, but continued to collect his pension from Metro. While working as a security guard at a department store in 1995, Knight reinjured his back. He remained on disability status until August of 1999, when he was reevaluated by his personal physician, Steven Kinney, and informed that he could return to work as a police officer without restrictions.

Knight delivered a letter to the Metropolitan Benefit Board from Dr. Kinney that same month authorizing him to return to work. In April of 2000, the Benefit Board recommended that Knight be allowed to return to his previous position as a police officer.

*758 At this point, the parties’ characterization of the subsequent events in this case diverge. According to Metro, arrangements were immediately made for Knight to attend a 13-week lateral-training course “to get [Knight] back up to speed on Metropolitan police procedure and make him a productive officer.” He did not begin the class as scheduled, however, because the Metropolitan Civil Service Clinic was unable to provide the medical clearance necessary for Knight’s admission into the class. Metro instead told Knight that he could enter the class late or enroll in the spring class, so long as he provided the Clinic with certain documents from his medical record. But Knight, according to Metro, did not furnish the documents and refused to attend the training course. Knight’s disability pension was eventually terminated because he purportedly refused to accept employment with Metro.

Not surprisingly, Knight’s account of his treatment is quite different. According to Knight, after he was cleared to return to work by the Benefit Board, Metro undertook a series of actions intended to prevent him from returning to the police force. He was repeatedly told that the Chief of Police, Emmett Turner, would never rehire an individual on a disability pension. The Chief himself told Knight that he was concerned that pensioners often returned to the police force for the sole purpose of obtaining a higher salary and then went back to disability status to collect a larger pension. So even though the Benefit Board recommended that Knight be rehired and there were openings on the police force, Metro allegedly made no legitimate efforts to rehire Knight. Eventually, Knight was informed that he could enroll in the lateral-training course, but was also told that his salary once he was rehired would be only one step above that of a new recruit.

Knight nevertheless showed up for the training course. On the first day, however, he was informed by Sergeant Kim Gooch, the director of the course, that he could not participate because he had not been medically cleared. Sergeant Gooch also told Knight that Metro had never rehired a pensioner, and that his offer of reemployment was conditional upon his performance in the class. Knight perceived this admonition to be a threat that, once he began the class, he would be fired if he did not meet the standards expected of new recruits, rather than those expected of returning disability pensioners. As a result, Knight chose not to complete the course and returned to his former job at the department store. Eventually, he was hired to work as a police officer in La Vergne, Tennessee.

Knight filed suit against Metro in May of 2001 in the United States District Court for the Middle District of Tennessee. He alleged that Metro’s refusal to allow him to return to the force was part of a department-wide unofficial policy of not rehiring disability pensioners. His case went to trial before a jury. The jury found that Metro regarded Knight as disabled, that Metro was aware that Knight had a record of a disability, and that Metro’s proffered reasons for failing to rehire Knight were pretextual. It awarded Knight $150,000 in compensatory damages. Ip addition, the judge awarded Knight an additional $27,482 in back pay and ordered that Knight be reinstated to his former position.

Metro moved (1) to alter or amend the judgment, (2) for judgment as a matter of law, and (3) for a new trial. All three motions were denied by the district court. The court explained that “[a]mple evidence was presented to support the jury’s findings that Metro both regarded the plaintiff as disabled and was aware that the plain *759 tiff had a record of a disability.” This appeal followed.

II. ANALYSIS

A. Standard of review

A district court’s refusal to grant a motion for judgment as a matter of law pursuant to Rule 50(a) of the Federal Rules of Civil Procedure is reviewed de novo. Jackson v. Quanex Corp., 191 F.3d 647, 657 (6th Cir.1999). We view the evidence in the light most favorable to the nonmoving party, Gray v. Toshiba Am. Consumer Prods., Inc., 263 F.3d 595, 598 (6th Cir. 2001), and will affirm the jury’s verdict unless there was “no legally sufficient evidentiary basis for a reasonable jury to find for [the prevailing] party.” Fed.R.Civ.P. 50(a).

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Bluebook (online)
136 F. App'x 755, Counsel Stack Legal Research, https://law.counselstack.com/opinion/knight-v-metropolitan-government-ca6-2005.