Merritt v. Arizona, State of

CourtDistrict Court, D. Arizona
DecidedApril 20, 2021
Docket2:17-cv-04540
StatusUnknown

This text of Merritt v. Arizona, State of (Merritt v. Arizona, State of) 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
Merritt v. Arizona, State of, (D. Ariz. 2021).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9 No. CV-17-04540-PHX-DGC 10 Leslie A. Merritt, Jr., ORDER 11 Plaintiff, 12 v. 13 State of Arizona, et al., 14 Defendants.

15 16 17 This action arises out of Plaintiff Leslie Merritt’s arrest, detention, and prosecution 18 for the I-10 freeway shootings in Phoenix, Arizona in August 2015. Plaintiff’s false arrest 19 and imprisonment claims against Defendant State of Arizona were tried to a jury last fall. 20 The jury returned a defense verdict. See Docs. 463, 469. 21 Pursuant to Rules 50 and 59 of the Federal Rules of Civil Procedure, Plaintiff now 22 moves for judgment notwithstanding the verdict and a new trial. Doc. 502. The motion is 23 fully briefed. Docs. 507, 510. The Court denies Plaintiff’s request for oral argument 24 because it will not aid the Court’s decision. See Fed. R. Civ. P. 78(b); LRCiv 7.2(f). For 25 reasons stated below, the Court will deny the motion. 26 I. Background. 27 Three shootings occurred on the I-10 freeway on August 29, 2015, and a fourth 28 between August 27 and 30, 2015. Plaintiff was arrested and indicted for the shootings in 1 September 2015. See State v. Merritt, CR2015-144211 (Maricopa Cty. Super. Ct. 2015). 2 He was released from custody and the charges against him were dismissed in April 2016. 3 Plaintiff pawned a Hi-Point C9 9mm handgun around 5:30 p.m. on August 30, 2015, 4 about four hours before Plaintiff alleges the fourth shooting occurred. The fourth shooting 5 involved Alfred Hackbarth’s BMW. Around 9:00 p.m. on August 30, Hackbarth landed at 6 Phoenix Sky Harbor Airport and returned to his BMW in the Terminal 2 parking garage, 7 where he had parked it three days earlier. The BMW’s front left tire lost pressure rapidly 8 on Hackbarth’s drive home. A bullet was found in the tire the next day. 9 The Arizona Department of Public Safety (“DPS”) recovered four bullets during its 10 investigation of the shootings, including the bullet found inside the BMW tire. On 11 September 7, 2015, the DPS crime lab identified all four bullets as coming from a Hi-Point 12 C9 9mm handgun. On September 17, officers located from various pawn shops eight 13 Hi-Point C9 9mm handguns to submit to the DPS crime lab for ballistics testing. The next 14 day, DPS criminalist Christopher Kalkowski identified one of the guns as the source of the 15 bullets recovered in all four shootings. A DPS officer reviewed the list for the pawned 16 guns and identified Plaintiff as the owner of the gun in question. 17 DPS officers arrested Plaintiff without a warrant on September 18. A grand jury 18 indicted him for the I-10 shootings six days later. In February 2016, while preparing for 19 trial, the Maricopa County Attorneys’ Office asked Lucien Haag to conduct an independent 20 firearms identification analysis. Haag’s findings were inconclusive – the four evidence 21 bullets could neither be excluded nor identified as having been fired from Plaintiff’s gun. 22 As a result, Plaintiff was released from jail on April 19, 2016. The charges against him 23 were dismissed without prejudice six days later. 24 Plaintiff filed suit against Maricopa County, various County officers and employees, 25 the State of Arizona, and various DPS officers and employees. Docs. 1, 8. Plaintiff later 26 dismissed the claims against the County Defendants. Docs. 41, 224. The remaining 27 Defendants – the State of Arizona and the DPS officers – moved for summary judgment. 28 Doc. 264. The Court granted summary judgment on all claims except state law false arrest, 1 false imprisonment, and aiding and abetting, with respect to any pre-indictment damages. 2 Doc. 278.1 The Court found that Defendants had failed to show as a matter of undisputed 3 fact that they had probable cause to arrest and detain Plaintiff before the indictment issued 4 given their failure to resolve the discrepancy between the ballistics evidence and the timing 5 of the BMW shooting. Id. at 4-14. 6 The false arrest and imprisonment claims against Defendant State of Arizona were 7 tried to a jury over an eight-day period in October and November 2020. See Docs. 447-63.2 8 The jury found Defendant not liable on each claim. Doc. 469. 9 II. Plaintiff’s Motion for Judgment as a Matter of Law Under Rule 50. 10 Plaintiff asks the Court to enter judgment notwithstanding the verdict. Doc. 502 11 at 2.3 Rule 50(a)(1) provides for motions for judgment as a matter of law during trial: 12 If a party has been fully heard on an issue during a jury trial and the court 13 finds that a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on that issue, the court may . . . grant a motion for 14 judgment as a matter of law against [that] party[.] 15 Fed. R. Civ. P. 50(a)(1)(B). Subsection (a)(2) states that a Rule 50(a) motion must be made 16 “before the case is submitted to a jury.” Fed. R. Civ. P. 50(a)(2); see Williams v. Gaye, 17 895 F.3d 1106, 1131 (9th Cir. 2018) (“Under Rule 50, a party must make a Rule 50(a) 18 motion for judgment as a matter of law before a case is submitted to the jury.”) (quoting 19 EEOC v. Go Daddy Software, Inc., 581 F.3d 951, 961 (9th Cir. 2009)). 20 Plaintiff made no Rule 50(a) motion during trial. See Doc. 507 at 2 & n.2. 21 Defendant argues that this failure is fatal to Plaintiff’s present motion under Rule 50. Id. 22

23 1 Because a post-arrest indictment cuts off the length of detention, and thus damages, 24 stemming from a false arrest, any damages recoverable on Plaintiff’s arrest-related claims were limited to the period between his arrest on September 18 and his indictment on 25 September 24, 2015. See id. at 6, 34-35 (citations omitted). 26 2 Plaintiff dismissed the aiding and abetting claim. Doc. 423. 27 3 Plaintiff seeks a “judgment notwithstanding the verdict” (Doc. 502 at 1), but for more than a decade that phrase and the term “directed verdict” have been combined and 28 simply termed “judgment as a matter of law.” Tortu v. Las Vegas Metro. Police Dep’t, 556 F.3d 1075, 1082 n.2 (9th Cir. 2009). 1 at 2-4. The Court agrees, and will deny Plaintiff’s Rule 50(a) motion as untimely. Fed. R. 2 Civ. P. 50(a)(2); see Williams, 895 F.3d at 1131; Tortu, 556 F.3d at 1081-83.4 3 III. Plaintiff’s Motion for a New Trial Under Rule 59. 4 A. Rule 59 Standard. 5 Rule 59 allows a district court to grant a new trial on all or some issues “for any 6 reason for which a new trial has heretofore been granted in an action at law in federal 7 court[.]” Fed. R. Civ. P. 59(a)(1)(A). Because “Rule 59 does not specify the grounds on 8 which a motion for a new trial may be granted,” the court is “bound by those grounds that 9 have been historically recognized.” Zhang v. Am. Gem Seafoods, Inc., 339 F.3d 1020, 1035 10 (9th Cir. 2003). These “grounds include: ‘that the verdict is against the weight of the 11 evidence, that the damages are excessive, or that, for other reasons, the trial was not fair to 12 the party moving.’” Dawkins v. City & Cty. of Honolulu, No. CIV. 10-00086 HG-KSC, 13 2012 WL 1982461, at *4 (D. Haw. May 31, 2012) (quoting Molski v.

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Merritt v. Arizona, State of, Counsel Stack Legal Research, https://law.counselstack.com/opinion/merritt-v-arizona-state-of-azd-2021.