Newman v. Berkley

District Court, C.D. Illinois·Decided May 15, 2021·No. 3:20-cv-03171·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS, SPRINGFIELD DIVISION

CALEB NEWMAN, ) ) Plaintiff, ) ) v. ) Case No. 20-cv-3171 ) BRANDON BERKLEY, ) in his individual capacity; ) AARON PICKETT, ) in his individual capacity; ) PAUL COOPER, ) in his individual capacity; and ) CITY OF LINCOLN, ) a municipal corporation, ) ) Defendant. )

OPINION TOM SCHANZLE-HASKINS, U.S. MAGISTRATE JUDGE: This matter comes before the Court on Defendants’ Motion to Bifurcate and Stay Discovery of Plaintiff’s Monell Claims (d/e 29) (Motion). For the reasons set forth below, the Motion is DENIED, with leave to refile the motion to bifurcate the trial after disposition of dispositive motions. BACKGROUND The individual Defendants Brandon Berkley, Aaron Pickett, and Paul Cooper (Individual Defendants) were police officers employed by the Defendant City of Lincoln, Illinois (City). Newman alleges that on July 13, 2019, the Individual Defendants were dispatched to the intersection of 5th Street and South Main in the City based on a complaint of reckless driving.

Upon reaching the scene, the Individual Defendants initiated a traffic stop of a car driven by Newman. Newman alleges claims against Individual Defendants for violating his right under the Fourth Amendment by using

excessive force and failing to intervene to stop the other Individual Defendants’ use of excessive force during the traffic stop. Newman also alleges state law claims against the Individual Defendants (collectively Individual Claims). Newman alleges claims against the City for direct

municipal liability under § 1983 pursuant to Monell v. Department of Social Services of City of New York, 436 U.S. 658 (1978) and City of Canton v. Harris, 489 U.S. 378 (1989). First Amended Complaint, Counts VIII and IX

(collectively Monell Claims). See First Amended Complaint (d/e 25). The Defendants have answered and disputed Newman’s version of events. See generally, Defendants’ Answer to Plaintiff’s First Amended Complaint (d/e 28) (Answer). The Individual Defendants have also

asserted a defense of qualified immunity, and all Defendants have raised one or more defenses under the Illinois Local Governmental and Local Governmental Employee Tort Immunity Act, 745 ILCS 10/101 et seq. (Tort Immunity Act). See Answer, First Affirmative Defense and Second Affirmative Defense.

The Defendants now ask the Court to bifurcate the trial of the Individual Claims from the trial of the Monell Claims and to stay the discovery and trial of the Monell Claims until after the trial of the Individual

Claims. Newman opposes the Motion. ANALYSIS The Court has broad discretion is deciding whether to bifurcate trials. Volkman v. Ryker, 736 F.3d 1084, 1089 (7th Cir. 2013). This Court may

order separate trials for convenience, to avoid prejudice, or to expedite and economize. Fed. R. Civ. P. 42(b). If one of these criteria is met, the Court may bifurcate trials as long as doing so will not prejudice the non-moving

party or violate the Seventh Amendment right to a jury trial in civil cases at law. Chlopek v. Federal Insurance Co., 499 F.3d 692, 700 (7th Cir. 2007). In evaluating convenience, prejudice, and judicial economy, this Court considers the following factors:

(1) whether the issues sought to be separately tried are significantly different from one another; (2) whether the issues are triable by a jury or the court; (3) whether the posture of discovery as to the respective issues suggests that they should or should not be tried together; and (4) whether the separate issues require testimony of different witnesses and documentary proof. Wells v. Coker, 2014 WL 716518, at *3 (C.D. Ill. February 25, 2014). At this early stage of this proceeding the Court has little information with which

to determine whether these factors weigh in favor or against bifurcation of the trial. The Monell claims and the Individual Claims share some common

issues. The § 1983 Individual Claims and the Monell Claims require proof that the Individual Defendants violated Newman’s Fourth Amendment Rights. Bifurcating the trial may mean that Newman would have to prove the Fourth Amendment claim twice; the same witnesses may be required to

testify in both trials. This would not promote judicial economy. The Monell Claims, however, require proof of additional elements not relevant to the Individual Claims. Newman must show in the Monell Claims

that the constitutional violations were caused by the City’s policies, practices, or customs, or by the City’s knowledge and that its training procedures created a substantial risk that the violations would occur and the City’s responsible officials had the requisite indifference or disregard for

the risk so created. Bifurcating the trials would simplify the trial of the Individual Claims by removing these issues from that trial. The Defendants argue that the trial on the Monell Claims would be

avoided completely if they prevailed on the Individual Claims. The Court disagrees. Avoiding a second trial is not a certainty at this juncture even if the Individual Defendants prevail on the Individual Claims. For example,

the Court could possibly direct a verdict at the close of evidence in a trial on the Individual Claims because the evidence demonstrated that the Individual Defendants were entitled to qualified immunity. See Rakovich v. Wade, 850 F.2d 1180, 1201-02 (7th Cir. 1988), overruled, in part, on other

grounds by Spiegla v. Hull, 371 F.3d 928, 942 (7th Cir. 2004). Newman may be entitled to proceed with the trial on the Monell Claims, however, because the City has no qualified immunity defense. -S-ee- -e-.g-.-, -R-u-ff-in-o- -v-.

Sheahan, 218 F.3d 697, 700 (7th Cir. 2000). The Court and the parties may have to go through a second trial even if the Individual Defendants prevail on qualified immunity in the first. See Thomas v. Cook County Sheriff’s Department, 604 F.3d 293, 305 (7th Cir. 2009); Wells, 2014 WL 716518, at

*4. On balance, the existence of separate issues does not weigh in favor or against bifurcation at this juncture. The current early posture of discovery does not demonstrate whether

bifurcation would promote convenience or judicial economy, or cause prejudice to Newman. Staying discovery on the Monell Claims may promote convenience and judicial economy if the discovery on the

Individual Claims produces information that demonstrates that the Individual Defendants did not violate Newman’s Fourth Amendment rights. If so, then the entire matter could be resolved at summary judgment on the

Individual Claims. Neither party nor witnesses would need to incur the costs of discovery on the Monell Claims. Discovery on the Individual Claims, however, may produce evidence

that supports Newman’s claims that his rights were violated. If so, staying discovery on the Monell Claims may result in deposing the same third-party witnesses a second time on additional issues in the Monell Claims.

Free access — add to your briefcase to read the full text and ask questions with AI

Newman v. Berkley, (C.D. Ill. 2021).

Newman v. Berkley (Newman v. Berkley) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related