Madsen v. City of Phoenix

CourtDistrict Court, D. Arizona
DecidedFebruary 16, 2023
Docket2:19-cv-03182
StatusUnknown

This text of Madsen v. City of Phoenix (Madsen v. City of Phoenix) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Madsen v. City of Phoenix, (D. Ariz. 2023).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Christina M. Madsen, No. CV-19-03182-PHX-GMS

10 Plaintiff, ORDER

11 v.

12 City of Phoenix,

13 Defendant. 14 15 16 Before the Court is Defendant City of Phoenix’s Renewed Motion for Judgment as 17 a Matter of Law or, in the alternative, Motion for New Trial or Remittitur of Damages 18 (Doc. 322). For the following reasons, the motion is granted in part and denied in part. 19 BACKGROUND 20 This case concerns Christina Madsen’s (“Plaintiff”) hostile work environment 21 (“HWE”) claim against the City of Phoenix (“Defendant”). At issue is the workplace 22 conduct of Michael Graci (“Mr. Graci”), an Assistant Aviation Director for the Defendant, 23 toward Plaintiff, who served as the Deputy Director of Business and Properties (“B&P”) 24 for the Defendant. This Court held a four-day jury trial from April 19-22, 2022, on the 25 HWE claim. At the conclusion of trial, Defendant filed a motion for judgment as a matter 26 of law under Federal Rule of Civil Procedure 50(a). Defendant based its motion on three 27 grounds: (1) Mr. Graci’s conduct was not “because of sex”; (2) Mr. Graci’s conduct 28 towards Plaintiff was not sufficiently severe or pervasive; and (3) the City is not liable 1 because it did not, and could not, have known about the alleged harassment. (Doc. 275.) 2 After briefing and oral argument, the Court denied the motion. (Doc. 315.) In 3 denying the motion, however, the Court isolated the five-week time period for which a 4 reasonable jury could have found that Plaintiff experienced a hostile work environment. 5 (Doc. 315 at 16.) Following the Order, Defendant filed a renewed motion for judgment as 6 a matter of law, or in the alternative, a motion for a new trial or remittitur. (Doc. 322.) 7 Defendant bases its motion for judgment as a matter of law on the same grounds as its 8 previous motion. In its motion for a new trial or remittitur, it raises four additional 9 arguments: (1) that the verdict was against the clear weight of the evidence, (2) that 10 Plaintiff’s counsel engaged in misconduct throughout the trial, (3) that the jury instructions 11 were erroneous, and (4) that the damages award was grossly excessive and unsupported by 12 the evidence. (Doc. 322.) 13 DISCUSSION 14 I. Legal Standard 15 On a Rule 50(a) motion for judgment as a matter of law, a district court may grant 16 judgment as a matter of law only if a “reasonable jury would not have a legally sufficient 17 evidentiary basis to find for the party on that issue.” Fed. R. Civ. P. 50(a)(1); see also 18 Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 149 (2000). In reviewing a Rule 19 50(a) motion, a court does not make credibility determinations or weigh the evidence. 20 Reeves, 530 U.S. at 150. A court must review the entire record, “draw all reasonable 21 inferences in favor of the nonmoving party,” id. at 150, and “may not substitute its view of 22 the evidence for that of the jury.” Krechman v. County of Riverside, 723 F.3d 1104, 1110 23 (9th Cir. 2013). “The test applied is whether the evidence permits only one reasonable 24 conclusion, and that conclusion is contrary to the jury’s verdict.” Josephs v. Pac. Bell, 443 25 F.3d 1050, 1062 (9th Cir. 2006). 26 On a Rule 59 motion for a new trial, the court may grant a new trial only if the 27 verdict is contrary to the clear weight of the evidence or “it is quite clear that the jury has 28 reached a seriously erroneous result.” Venegas v. Wagner, 831 F.2d 1514, 1519 (9th Cir. 1 1987). On a Rule 59 motion, “the district court can weigh the evidence, make credibility 2 determinations, and grant a new trial for any reason necessary to prevent a miscarriage of 3 justice.” Experience Hendrix L.L.C. v. Hendrixlicensing.com Ltd., 762 F.3d 829, 841 (9th 4 Cir. 2014). “Unlike with a Rule 50 determination, the district court, in considering a Rule 5 59 motion for a new trial, is not required to view the trial evidence in the light most 6 favorable to the verdict.” Id. A court may also grant a new trial based on the failure to 7 give adequate jury instructions, erroneous jury instructions, or attorney misconduct. 8 Murphy v. City of Long Beach, 914 F.2d 183, 187 (9th Cir. 1990); Bird v. Glacier Elec. 9 Coop., Inc., 255 F.3d 1136, 1145 (9th Cir. 2001). 10 Additionally, the jury’s determination as to the appropriate damages award is to be 11 afforded “substantial deference.” Passantino v. Johnson & Johnson Consumer Prods., 12 Inc., 212 F.3d 493, 511 n.16 (9th Cir. 2000). Therefore, a damages award should only be 13 set aside if the amount is clearly unsupported by the evidence or grossly excessive. Id.; 14 Lambert v. Ackerley, 180 F.3d 997, 1011 (9th Cir. 1999). “When the court, after viewing 15 the evidence concerning damages in a light most favorable to the prevailing party, 16 determines that the damages award is excessive, it has two alternatives. It may grant 17 defendant’s motion for a new trial or deny the motion conditional upon the prevailing party 18 accepting a remittitur.” Fenner v. Dependable Trucking Co., 716 F.2d 598, 603 (9th Cir. 19 1983). 20 II. Analysis 21 A. Judgment as a Matter of Law 22 The City’s Motion for Judgment as a Matter of Law is denied. In its motion, the 23 City renews its earlier Rule 50(a) motion without providing any reason that the Court 24 should revisit its earlier order. Without any new argument or changed circumstances, the 25 Court’s analysis in the order denying judgment as a matter of law (“JMOL Order”) 26 (Doc. 315) remains the same. As such, Defendant’s motion is denied. 27 B. New Trial or Remittitur 28 1. Defendant’s Notice and Remedial Response 1 The jury’s finding that Defendant was on notice of a hostile work environment and 2 failed to remedy the harassment is against the clear weight of the evidence. To succeed on 3 her hostile work environment claim, Plaintiff needed to show that Defendant “knew, or in 4 the exercise of reasonable care should have known” of the hostile work environment and 5 “fail[ed] to remedy or prevent it.” McGinest v. GTE Serv. Corp., 360 F.3d 1103, 1119 (9th 6 Cir. 2004). The employer’s remedy should be “reasonably calculated to end the 7 harassment.” Ellison v. Brady, 924 F.2d 872, 882 (9th Cir. 1991). As the Ninth Circuit 8 has said, “[a]n employer’s remedy should persuade individual harassers to discontinue 9 unlawful conduct. We do not think that all harassment warrants dismissal; rather remedies 10 should be assessed proportionately to the seriousness of the offense.” Id. (internal citations 11 and quotations omitted). 12 The JMOL Order explains that a reasonable jury could not have found that 13 Defendant was on notice of a hostile work environment any earlier than March 27, 2018, 14 when Plaintiff alleges that she notified the City she was threatened or intimidated in 15 meeting with Mr. Graci one-on-one.

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Madsen v. City of Phoenix, Counsel Stack Legal Research, https://law.counselstack.com/opinion/madsen-v-city-of-phoenix-azd-2023.