Moss v. City and County of San Francisco

CourtDistrict Court, N.D. California
DecidedApril 30, 2025
Docket3:22-cv-01252
StatusUnknown

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

Bluebook
Moss v. City and County of San Francisco, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 CECIL H. MOSS, Case No. 22-cv-01252-JSC

8 Plaintiff, ORDER RE: DEFENDANT’S MOTION 9 v. FOR JUDGMENT AS A MATTER OF LAW AND PLAINTIFF’S MOTION TO 10 CITY AND COUNTY OF SAN AMEND JUDGMENT FRANCISCO, 11 Re: Dkt. Nos. 190, 191, 196 Defendant.

12 13 Cecil H. Moss, Jr. sued the City and County of San Francisco (“the City”) alleging 14 disability discrimination in violation of the California Fair Housing and Employment Act 15 (“FEHA”). After a five-day trial, the jury rendered a verdict for Mr. Moss on both his claims, 16 finding the City (1) failed to provide reasonable accommodation for Mr. Moss’s disability, and (2) 17 failed to engage in a good-faith interactive process. The jury awarded Mr. Moss $255,116 in lost 18 wages. Accordingly, on January 28, 2025, the Court entered judgment in favor of Mr. Moss and 19 against the City in the amount of $255,116. (Dkt. No. 172.) 20 Pending before the Court are (1) the City’s motion for a new trial, or in the alternative, for 21 judgment notwithstanding the verdict; and (2) Mr. Moss’s motion to amend the judgment. Having 22 carefully considered the parties submissions, and with the benefit of oral argument on April 29, 23 2025, the Court DENIES the City’s motion. Substantial evidence supports the jury’s verdict, and 24 the City fails to demonstrate how any of the asserted errors caused substantial prejudice. And the 25 Court GRANTS in part and DENIES in part Mr. Moss’s motion to amend the judgment. The 26 Court amends the judgment to correct a calculation error and to award post-judgment interest. But 27 because disputes of fact rendered the damages amount uncertain, Mr. Moss is not entitled to 1 DISCUSSION 2 I. THE CITY’S MOTION FOR JUDGMENT AS A MATTER OF LAW 3 A Rule 50(b) motion for judgment as a matter of law is proper when “the evidence permits 4 only one conclusion and that conclusion is contrary to the jury’s verdict.” Martin v. California 5 Dep’t of Veterans Affs., 560 F.3d 1042, 1046 (9th Cir. 2009). The court must view the evidence in 6 the light most favorable to the nonmoving party and draw all reasonable inferences in that party’s 7 favor. E.E.O.C. v. Go Daddy Software, Inc., 581 F.3d 951, 961 (9th Cir. 2009). The court “may 8 not make credibility determinations or weigh the evidence.” Reeves v. Sanderson Plumbing 9 Prods., Inc., 530 U.S. 133, 150 (2000). A “jury’s verdict must be upheld if it is supported by 10 substantial evidence, which is evidence adequate to support the jury’s conclusion, even if it is 11 possible to draw a contrary conclusion.” Pavao v. Pagay, 307 F.3d 915, 918 (9th Cir. 2002). 12 A Rule 50(b) “is not a freestanding motion” but “a renewed Rule 50(a) motion.” Go 13 Daddy Software, 581 F.3d at 961. As the Ninth Circuit explained:

14 Because it is a renewed motion, a proper post-verdict Rule 50(b) motion is limited to the grounds asserted in the pre-deliberation Rule 15 50(a) motion. Thus, a party cannot properly raise arguments in its post-trial motion for judgment as a matter of law under Rule 50(b) 16 that it did not raise in its preverdict Rule 50(a) motion.

17 Id. (cleaned up). 18 During trial, the City orally “mov[ed] for relief under Rule 50(a) on the following 19 grounds”: 20 (1) “there is no competent evidence that . . . contradict[s] . . . Ms. Holland’s testimony and Dr. Valmassy’s report requirement of 15 21 minutes of sitting per hour as being incompatible with the essential functions of the 8214 parking control officer position”; 22 (2) “there is . . . no competent testimony of evidence regarding the essential functions of the parking control officer role”; 23 (3) “other than the 8214 parking control officer position, there is no evidence in the record establishing the essential functions for any 24 of the other roles”; (4) “[f]or the 8214 parking control officer role, there is no competent 25 evidence that a vacancy existed at any relevant time”; (5) “there is no competent evidence that Mr. Moss provided 26 verification of his prior experience as a 2708 custodian and 9102 transit car cleaners -- transit car cleaner positions”; and 27 (6) the City’s affirmative defense “should be established as a matter of law.” 1 (Dkt. No. 177 at 19-24.) The City now moves for judgment as a matter of law under Rule 50(b) 2 on both the failure to accommodate and the failure to engage in the interactive process claims. 3 A. Failure to Accommodate 4 On Claim One, the jury found the City failed to provide reasonable accommodation for 5 Mr. Moss’s disability. (Dkt. No. 169 at 1.) The City insists it is entitled to judgment as a matter 6 of law on this claim because Mr. Moss did not establish there was a vacant eligible position in 7 which he could be accommodated. According to the City, Mr. Moss had to “show both that he 8 possesse[d] the qualifications for a position, meaning the relevant skills and background 9 professionally required for a position, and that he [could] physically perform the essential 10 functions of the job, meaning those functions for which the job was created and which are critical 11 to the performance of the job.” (Dkt. No. 196 at 6-7.) The City argues there was no position for 12 which Mr. Moss established both requirements. 13 As an initial matter, while the City’s Rule 50(a) motion raises the essential functions 14 argument, it does not raise the minimum qualifications argument with respect to the School 15 Crossing Guard position. A “Rule 50(b) may be satisfied by an ambiguous or inartfully made 16 motion under Rule 50(a)” to avoid harsh results. See Go Daddy Software, 581 F.3d at 961. But 17 even construing “verification” as “minimum qualification,” the City’s Rule 50(a) motion stated 18 “there [was] no competent evidence that Mr. Moss provided verification of his prior experience as 19 a 2708 custodian and 9102 transit car cleaners” positions. (Dkt. No. 177 at 23.) The City did not 20 argue a lack of evidence regarding Mr. Moss’s verification for the 8201 School Crossing Guard 21 position. And as the parties agree, the jury’s verdict was based on the School Crossing Guard 22 position. (Dkt. No. 196 at 19 (the City’s motion stating the “amount awarded to Plaintiff is based 23 on Plaintiff’s assertion that he would have earned that amount between the time he received the 24 job and trial if Plaintiff had been accommodated via the School Grossing Guard position.”); Dkt. 25 No. 200 at 8-9 (Mr. Moss’s motion stating “the relevant position for . . . the Motion for a judgment 26 notwithstanding is the Crossing Guard position, the position on which the verdict was based”).) 27 The City’s reply ignores that its Rule 50(b) motion improperly raises a new argument. 1 supports a finding Mr. Moss was qualified for the School Crossing Guard position. Mariana 2 Valdez, a reasonable accommodation coordinator, testified the seven positions listed in Trial 3 Exhibit 13 (Docket No. 178-9)—including the 8201 School Crossing Guard position—were 4 || positions for “which Mr. Moss met the minimum qualifications.” (Dkt. No. 175 at 46.) This 5 alone is substantial evidence supporting the jury’s finding that “Cecil Moss was able to perform 6 || the essential job duties of a vacant City position.” (Dkt. No. 169 at 1.) Drawing all reasonable 7 || inferences in Mr. Moss’s favor, a jury could conclude from this testimony Mr.

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Bluebook (online)
Moss v. City and County of San Francisco, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moss-v-city-and-county-of-san-francisco-cand-2025.