Rentas v. Ruffin

816 F.3d 214, 99 Fed. R. Serv. 1255, 2016 U.S. App. LEXIS 4306, 2016 WL 877828
Court of Appeals for the Second Circuit·Decided March 8, 2016·No. Nos. 14-2475-cv, 14-2512-cv·Published·Cited by 88 cases

Opinion

LOHIER, Circuit Judge:

Axel Rentas appeals, and Captain John Ruffin cross-appeals,, from a judgment of the United States District Court for the Southern , District of New York (Heller-stein, /.). Rentas, a former inmate on Rikers Island, sued several correction officers and prison officials along with the City of New York, claiming that the officers used excessive force against him and then fabricated evidence, leading to his prosecution and prolonged detention. Because we conclude that the District Court committed a significant evidentiary error by excluding certain reports prepared by the officers, we VACATE in part and REMAND for further proceedings consistent with this opinion. As for Captain Ruffin’s cross-appeal, in which he argues that he was entitled to judgment as a matter of law on Rentas’s claim for intentional infliction of emotional distress, we AFFIRM.

[219] BACKGROUND

This case arises from a July 12, 2007 altercation between. Rentas, then an inmate on Rikers Island, and several members of the correctional staff. Rentas was serving a misdemeanor sentence and was scheduled to be released in less than three weeks. - Correction Officer Kevin Parker ordered Rentas to move to a new bed, but Rentas refused, asking to speak with. Parker’s supervisor. A fight started when Officer Parker attempted to move Rentas’s belongings from near his bed. Another officer called for backup. The fight escalated when Captain Ruffin and other correctional staff arrived. The officers- eventually subdu'ed Rentas, handcuffed him, and carried him away.

The parties disagree about who initiated the fight, the degree to which Rentas resisted, and whether he was injured before or after the Rikers staff placed him -in handcuffs. According to Rentas, Officer Parker. grabbed him when he refused to change beds and then fell on purpose, feigning injury. When Captain Ruffin arrived, he immediately placed- Rentas in handcuffs. Rentas claims that Captain Ruffin and other correction officers then proceeded to punch, kick, and pepper spray him while he was handcuffed. As they carried him away, they purposefully dropped him on his face. And after arriving at intake, Deputy Wardens Walter Nin and Elisio Perez allegedly joined in, beating Rentas while he remained in handcuffs. Rentas suffered a -fractured' eye socket, bruises and abrasions all- over his body, and bleeding in his lungs. Several of the correction officers involved in' the incident also complained of injuries: and received medical treatment. Later that month, Rentas filed a notice of claim with the City alleging it was responsible for violations of his- civil rights and related claims.

As part of an internal New York City Department of Corrections investigation into the incident, several of the correctional staff—Captains Ruffin, Darryll Lago, and Sharon Clayton, and Officers Diana Baker, Kevin Parker, and George Ruppel—prepared reports of the incident, which were ultimately transmitted to an Assistant District Attorney in Bronx County. Shortly thereafter, Rentas was charged in Bronx County Criminal Court with multiple counts.of felony assault and detained for three years before being acquitted at trial.

. After his acquittal, Rentas sued the correctional staff involved in the July 2007 altercation, along with the City.of New York, claiming the defendants were liable for the use of excessive force, assault and battery, malicious prosecution, the denial of his right to a fair trial, intentional infliction of emotional distress (“IIED”), and the failure to intercede'to protect him from the violation of his constitutional rights. Oh sunimaiy judgment, Rentas claimed that the reports prepared by the correctional staff were false and had prompted the prosecution. The District Court dismissed Rentas’s malicious prosecution claim, reasoning that the Bronx County “prosecutors [had] exercised an independent decision to prosecute based on ... evidence of the officers’ Injuries' and the statements of other inmates who claimed that [Rentas] started the altercation.” It refused to dismiss' Rentas’s IIED claim, however, explaining that his notice of claim satisfied the requirements of New York’s General Municipal Law.. The parties proceeded to trial on all of the remaining felaims. At trial, Rentas sought to admit the officers’’ use-of-force reports and other documents that the defendants prepared and later provided to the Bronx District Attorney’s office. Although the District Court admitted ■ several of the reports, it excluded five of them as inadmissible hear[220] say. During a jury charge conference, Rentas objected to the District Court’s proposed instruction to the jury that it could award Rentas nominal damages for his fair trial and excessive force claims; he also challenged the District Court’s refusal to instruct the jury on assault and battery under New York State law in connection with the excessive force claim.

The jury found Captain Ruffin individually liable for denying Rentas’s right to a fair trial, subjecting him to excessive force, and failing to intercede, and all the defendants liable for IIED. It awarded Rentas $67,500 in compensatory damages for the IIED claim, but only nominal damages for the fair trial, excessive force, and failure to intercede claims.

This appeal followed.

DISCUSSION

On appeal, Rentas argues that the District Court erred by dismissing his malicious prosecution claim on summary judgment and excluding the officers’ reports from evidence. We agree and therefore vacate in part the District Court’s judgment and remand for a new trial on the malicious prosecution, excessive force, failure to intercede, and fair trial claims. Captain Ruffin cross-appeals, arguing that he was entitled to judgment as a matter of law on Rentas’s IIED claim. We are not persuaded, however, that.the jury’s verdict on the IIED claim should be disturbed and therefore affirm the District .Court’s judgment as to that claim.

1., Malicious Prosecution

We turn first ;to. the District Court’s dismissal of Rentas’s malicious prosecution claim. We review the District Court’s grant of summary judgment de novo, construing all evidence in the light most favorable to the non-moving party. Ruggiero v. County of Orange, 467 F.3d 170, 173 (2d Cir.2006). Summary judgment should be affirmed only when there is no genuine dispute as to a material fact and the movant is entitled to judgment as a matter of law. Fed.R.Civ.P. 56(a).

In order to prevail on his malicious prosecution claim, Rentas was required to show the following: “(1) the defendant initiated a prosecution against plaintiff, (2) without probable cause to believe the proceeding can succeed, (3) the proceeding was begun with malice[,] and[] (4) the matter terminated in plaintiffs favor.” Cameron v. City of New York, 598 F.3d 50, 63 (2d Cir.2010) (quoting Ricciuti v. N.Y.C. Transit Auth., 124 F.3d 123, 130 (2d Cir.1997)). Here, the defendants initiated a prosecution against Rentas and the matter terminated in his favor.

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Rentas v. Ruffin, 816 F.3d 214, 99 Fed. R. Serv. 1255, 2016 U.S. App. LEXIS 4306, 2016 WL 877828 (2d Cir. 2016).

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