Meadows v. State University of New York

160 F.R.D. 8, 1995 U.S. Dist. LEXIS 1082, 1995 WL 31706
CourtDistrict Court, N.D. New York
DecidedJanuary 24, 1995
DocketCiv. No. 92-CV-1492
StatusPublished
Cited by5 cases

This text of 160 F.R.D. 8 (Meadows v. State University of New York) is published on Counsel Stack Legal Research, covering District Court, N.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Meadows v. State University of New York, 160 F.R.D. 8, 1995 U.S. Dist. LEXIS 1082, 1995 WL 31706 (N.D.N.Y. 1995).

Opinion

DECISION AND ORDER

SCULLIN, District Judge:

I. INTRODUCTION

Plaintiffs JoAnn Meadows and Patricia Smouse originally brought this action against the State University of New York at Oswego (“SUNY Oswego”) and Dr. Stephen Weber, President; Dr. Jane Milley, Provost; Deborah Stanley, Executive Assistant to the President; Dr. Sandra Moore, Athletic Director; Dr. Bruce Lester, Interim Athletic Department Chairman; and Marta Santiago, Affirmative Action Officer; in their individual and official capacities. The complaint alleged violations of Title IX, 20 U.S.C. § 1681 et seq.; Title VII retaliation, 42 U.S.C. § 2000e-3; Title VII gender discrimination, 42 U.S.C. § 2000e-2; 42 U.S.C. § 1983; 42 U.S.C. § 1985(3); 42 U.S.C. § 1986; the First Amendment to the Constitution of the United States; New York Civil Service Law § 75-b; and New York Executive Law § 290 et seq.

The Title IX claim, the 42 U.S.C. § 1986 claim, and the First Amendment claim were dismissed, with the consent of all parties, as duplicative of the remaining claims. The 42 U.S.C. § 1983 claims against SUNY Oswego and each defendant in his/her official capacity were dismissed as violative of the immunity from suit afforded to states under the Eleventh Amendment. The court, thereafter, with the approval of the parties, bifurcated the trial as to liability and damages and proceeded to trial only on the issue of liability. The trial was held from November 28, 1994 through December 14, 1994.

During the course of the trial, the plaintiffs withdrew their state law claims (NY Civ.Ser.Law § 75-b and NY Exec.Law § 290 et seq.). At the close of plaintiffs’ case, the [10]*10court dismissed both plaintiffs’ 42 U.S.C. § 1985(3) conspiracy claims on the grounds of insufficient evidence. Additionally, the court dismissed plaintiff Meadows’ Title VII discrimination claim as to all defendants because she failed to establish any discriminatory basis for the employment actions taken against her.1 And finally, the court dismissed all of the remaining claims against defendants Lester, Stanley, Santiago and Milley on the basis that the evidence clearly showed that they were not responsible for any of the adverse employment actions at issue.

On December 14, 1994, the remaining claims were submitted to the jury. These claims consisted of:

Plaintiff Meadows—

1) 42 U.S.C. § 1983 claim against Dr. Weber and Dr. Moore; and
2) Title VII retaliation claim against Dr. Weber, Dr. Moore and SUNY Oswego;

Plaintiff Smouse—

1) 42 U.S.C. § 1983 claim against Dr. Weber;
2) Title VII retaliation claim against Dr. Weber and SUNY Oswego; and
3) Title VII discrimination claim against Dr. Weber and SUNY Oswego.

On December 15, 1994, the jury returned a verdict finding in favor of defendants on all claims except for plaintiff Smouse’s Title VII retaliation claim. With respect to Smouse’s Title VII retaliation claim, the jury found that SUNY Oswego, acting through its “agents,” had retaliated against her for her complaints of gender discrimination.

Presently before the court are the defendants’ Rule 50 motions for judgment as a matter of law which were brought at the close of plaintiffs’ case, and which defendants renewed after the jury returned its verdict.2 In determining whether to grant a judgment as a matter of law pursuant to Rule 50, the court must examine the entire record in the light most favorable to the non-moving party. Mattivi v. South African Marine Corp., “Huguenot”, 618 F.2d 163, 167-68 (2d Cir.1980).

In evaluating the Rule 50 motions, the court has reviewed the evidence as contained in the trial record and considered the arguments set forth by both parties in their post-trial submissions. The court notes at the outset that its review of the evidence was hindered by the failure of either party to develop a clear factual record. Despite the court’s constant admonishment to focus on the relevant elements of the causes of action, neither plaintiffs nor defendants were able to establish clear facts in support of their respective positions. The evidence presented was barely sufficient to warrant submitting this case to the jury; however, the court decided to do so with the assistance of special verdict forms.

Notwithstanding the use of the special verdict forms, the jury’s answers to the ques[11]*11tions posed there now require the court to again review the evidence pursuant to Rule 50 standards. Although the court believes it may be justified, in light of the paucity of relevant evidence, to grant a judgment as a matter of law for the defendants, it will not do so. Instead, in the interest of justice and because the Court finds the jury’s answers to the questions in the special verdict forms to be inconsistent under a Rule 49 analysis, the court will order a partial retrial, pursuant to Rule 59 of the Federal Rules of Civil Procedure, as to plaintiff Smouse’s Title VII retaliation claim, against SUNY Oswego and Dr. Weber.

II. INCONSISTENT FINDINGS UNDER RULE 49

As stated above, at the close of the case the court submitted special verdict forms to the jury pursuant to Rule 49 of the Federal Rules of Civil Procedure. These special verdict forms consisted of “a series of questions of adjudicative fact[s] to be answered by the jury.” Denny v. Ford Motor Co., 42 F.3d 106, 111 (2d Cir.1994). Because the court did not require the jury to return a general verdict in addition to these questions, the submission of the special verdict forms is governed by Rule 49(a) of the Federal Rules of Civil Procedure. Avic Amusements, Inc. v. Angellotti

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Cite This Page — Counsel Stack

Bluebook (online)
160 F.R.D. 8, 1995 U.S. Dist. LEXIS 1082, 1995 WL 31706, Counsel Stack Legal Research, https://law.counselstack.com/opinion/meadows-v-state-university-of-new-york-nynd-1995.