Palmer v. Smith

District Court, D. New Hampshire·Decided December 15, 1997·No. CV-95-598-SD·Published

Opinion

Palmer v. Smith CV-95-598-SD 12/15/97 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

B. Irene Palmer; Donald Palmer

v. Civil No. 95-598-SD

David Smith, et al

O R D E R

At this stage of the proceedings, the court considers the complex issues arising from the inability of a trial jury to resolve all issues presented to it at trial.

1. Procedural Background Plaintiffs B. Irene Palmer and Donald Palmer are husband and wife. The claims at issue stem from incidents which occurred during the employment of Mrs. Palmer at a nursing home located in Peterborough, New Hampshire. The defendants are David Smith, at relevant times the administrator of said nursing home; Richard Daigle, a former bailiff at the Peterborough District Court; and Bruce McCall, a Peterborough police officer.

Plaintiffs launched a multitude of complaints against these defendants, as well as the owners and operators of the nursing

home.1 At the conclusion of trial, the issues were presented to the jury by medium of special verdict questions.

As against defendant Smith, the claims included his participation in an alleged false arrest of Mrs. Palmer which occurred at the nursing home on March 31, 1995. Additionally, it was claimed that over a longer period of time Smith had engaged in conduct, intentional and negligent, which was defamatory of and causative of emotional distress to Mrs. Palmer. This included the display in his office of a xerox copy of a certain photograph of Mrs. Palmer which had been taken at an earlier office Christmas party. It was also charged that Smith's conduct was such as to be sexually harassing in nature and to create a hostile work environment.

The jury found for Mrs. Palmer against Smith on her claim of false arrest at common law, and awarded her $2,000 for damages on that claim. The jury found for Smith on the claims of intentionally caused emotional distress, defamation arising from the false arrest, and battery arising from such false arrest. The jury failed to decide the issues as to whether Smith's participation in the false arrest was violative of Mrs. Palmer's civil rights; whether Smith's conduct was negligently causative

IPrior to trial, the owner/operators Sowerby Health Care, Inc., and Pheasant Wood Nursing Home, Inc., settled with the Palmers for the sum of $25,000.

of her emotional distress; whether his conduct was defamatory concerning display of the copy of the Christmas party photograph; whether Smith engaged in conduct against Mrs. Palmer which was sexually harassing and creative of a hostile work environment; and whether Mr. Palmer was entitled to recover for his loss of consortium. The jury also failed to answer a series of guestions the answers to which were designed to determine whether Smith was entitled to the coverage of a certain insurance policy.2 Finally, the jury did not answer any guestions concerning the plaintiffs' claims to recover punitive damages.

The claims against defendant Richard Daigle were concerned only with the March 1995 false arrest incident. As to Daigle, the jury found that Mrs. Palmer was entitled to recover for false arrest at common law, and also found that Daigle committed battery against her. The jury found for defendant Daigle on the claim of defamation. The resulting damages awarded against Daigle were the sum of $4,000 for the false arrest at common law and $2,000 for the battery.

The jury failed to return verdicts on the issues of whether

The policy was issued by Allstate Insurance Company, which had brought a declaratory judgment action in advance of trial seeking to determine the scope of its coverage. Prior to trial, this declaratory judgment was consolidated with the action on the merits, and the court ruled that the jury would answer certain special interrogatories (numbered 10 through 14) designed to determine the issue of coverage.

Daigle's participation in the false arrest was violative of Mrs. Palmer's civil rights; the right of Mr. Palmer to recover for loss of consortium; and punitive damages.

As to defendant McCall, whose only connection was with the false arrest incident, the jury found for Mrs. Palmer on her claim of false arrest at common law and found for McCall on the claims of defamation and battery. The resulting award was the sum of $1,800 against McCall.

Again, the jury failed to answer the guestions as to whether McCall's actions were violative of Mrs. Palmer's civil rights; whether Mr. Palmer was entitled to recover for loss of consortium; and punitive damages.

2. Discussion If a jury fails to answer all the guestions submitted in a special verdict, the verdict may be accepted for those issues that are resolved. Simms v. Village of Albion, N Y , 115 F.3d 1098, 1105 (2d Cir. 1997); Quaker City Gear Works, Inc. v. Skil Corp., 747 F.2d 1446, 1453 (Fed. Cir. 1984), cert,denied, 471 U.S. 1136 (1985). A partial retrial may thereafter be ordered only as to those issues which were not unanimously agreed upon by the jury. Baxter Healthcare Corp. v. Spectramed, Inc., 49 F.3d 1575, 1581 (Fed. Cir.), cert, denied, ___ U.S. ___, 116 S. C t .

272 (1995) .

Additionally, if a case is submitted to a jury and the jury is unable to return a verdict, the district court may still enter judgment as a matter of law. 9 M o o r e 's F e d e r a l Practice § 50.04 [2], at 50-19 (3d ed., Matthew Bender 1997); Hedgepeth v. Fruehauf Corp., 634 F. Supp. 93, 95 (S.D. Miss. 1986), aff'd without opinion, 813 F.2d 405 (5th Cir. 1987). And finally, where, as here, there has been a release given to one of two or more persons liable in tort for the same injury, the claim of the releasing person against other persons is to be reduced by the amount of compensation paid for the release. New Hampshire Revised Statutes Annotated (RSA) 507:7-h, 7-i;3 Waters v. Hedberg, 126 N.H. 546, 549-50, 496 A.2d 333, 335-36 (1985).4 Careful consideration of these factors leads the court to

RSA 507:7-h provides that, while a release "does not discharge any other person liable upon the same claim unless its terms expressly so provide . . . [i]t reduces the claim of the releasing person against other persons by the amount of the consideration paid for the release."

RSA 507:7-1 forbids the introduction at trial of any settlement had with a co-defendant, but provides that "upon return of a verdict for the plaintiff by the jury in any such trial, the court shall inguire of counsel the amount of consideration paid for any such settlement . . . and shall reduce the plaintiff's verdict by that amount."

Waters v. Hedberg, supra, considered the application of the now-repealed RSA 507:7-b, a predecessor statute which also provided for reduction of claims against co-defendants by the amount of consideration contained in a release.

conclude that, while there must be a partial retrial as to defendant Smith, judgments may and should now be entered, as hereinafter directed, in the cases against defendants Daigle and McCall.

a. Judgment as a Matter of Law Faced with a motion for judgment as a matter of law, a court must scrutinize the proof and the inferences reasonably to be drawn therefrom in the light most favorable to the non-movant. Gibson v. City of Cranston, 37 F.3d 731, 735 (1st Cir. 1994). The court may not consider the credibility of witnesses, resolve conflicts in testimony, or evaluate the weight of the evidence, and may grant the judgment only if the evidence, viewed from the perspective most favorable to the non-movant, is so one-sided that the movant is plainly entitled to judgment, for reasonable minds could not differ as to the outcome. Id.

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