Richard v. Fischer

CourtDistrict Court, W.D. New York
DecidedMarch 13, 2025
Docket6:11-cv-06013
StatusUnknown

This text of Richard v. Fischer (Richard v. Fischer) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richard v. Fischer, (W.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

JOHN WILLIS RICHARD, DECISION AND ORDER Plaintiff, v. 6:11-CV-06013 EAW

JENNIFER DIGNEAN and THOMAS TANEA,

Defendants.

Pro se plaintiff John Willis Richard (“Plaintiff”) commenced this action on December 3, 2010, pursuant to 42 U.S.C. § 1983. (Dkt. 1). Plaintiff asserted various claims against several New York State Department of Corrections and Community Supervision (“DOCCS”) personnel, alleging that they conspired to and committed various instances of discriminatory, retaliatory, and harassing conduct to unlawfully isolate his cellblock programming. (Dkt. 1). On March 11, 2024, the case proceeded to a jury trial on two causes of action: (1) an Equal Protection claim against Jennifer Dignean (“Dignean”) and Thomas Tanea (“Tanea”) (collectively, “Defendants”); and (2) a First Amendment retaliation claim against Tanea. (Dkt. 206). On March 15, 2024, the jury found in Plaintiff’s favor on the Equal Protection claim against Tanea, but otherwise found in Defendants’ favor. (Id.). The jury awarded Plaintiff $1.00 in nominal damages. (Id.). Pending before the Court is Tanea’s motion for judgment as a matter of law, filed under Rule 50(b)(2) of the Federal Rules of Civil Procedure. (Dkt. 215). Plaintiff filed a response to the motion on May 20, 2024.1 (Dkt. 218). For the reasons explained below, Tanea’s motion is denied. BACKGROUND

Plaintiff commenced this action on December 3, 2010, in the Northern District of New York. (Dkt. 1). On January 6, 2011, the case was transferred to this district. (Dkt. 6). On August 7, 2014, the Court granted in part and denied in part a motion to dismiss and dismissed all defendants except for Dignean and Tanea. (Dkt. 22). The Decision and Order held that Plaintiff’s second cause of action, alleging violation of the Equal

Protection Clause as against both Defendants, and Plaintiff’s third cause of action, alleging a First Amendment retaliation claim against Tanea, remained the sole claims in the case. (Id.). On August 27, 2014, Defendants filed an answer (Dkt. 23), and the case was referred to former United States Magistrate Judge Marian W. Payson for all pretrial matters excluding dispositive motions (Dkt. 24).

On October 4, 2019, the Court issued a Decision and Order granting a motion to compel filed by Plaintiff, and imposing sanctions on Defendants for their failure to timely respond to Plaintiff’s request for documents. (See Dkt. 96). Many documents sought by

1 Plaintiff asserts in response to Tanea’s Rule 50(b) motion that the jury’s verdict was erroneous. To the extent Plaintiff is attempting to make his own motion for judgment as a matter of law, the Court notes that Plaintiff did not make any such motion at trial, and therefore he would be precluded from raising one now, see McCarter & English, LLP v. Jarrow Formulas, Inc., 715 F. Supp. 3d 281, 303 (D. Conn. 2024) (“A party who does not move for judgment as a matter of law under Rule 50(a) is barred from challenging the verdict under Rule 50(b). This procedural requirement ‘may not be waived by the parties or excused by the district court.’” (internal citations omitted)), and any such motion also would be untimely, see Fed. R. Civ. P. 50(b) (time limit for making motion is “no later than 28 days after the entry of judgment”). Plaintiff in discovery had been destroyed after a five-year retention period pursuant to DOCCS policy. (Id.). Thereafter, on December 7, 2021, following an evidentiary hearing, the Court concluded that Plaintiff was entitled to an adverse inference instruction

at trial, based on Defendants’ spoliation of the aforementioned evidence—including cellblock move sheets and the logbook documenting inmate movement between blocks.2 (See Dkt. 111). Defendants filed a motion for summary judgment on July 29, 2022 (Dkt. 129), which the Court denied on March 13, 2023 (Dkt. 156). The case proceeded to trial on

March 11, 2024. (See Dkt. 200). Following the close of Plaintiff’s direct case, Defendants moved pursuant to Rule 50 for a directed verdict. As for the Equal Protection claim, Defendants argued that Plaintiff failed to prove he was treated differently than others similarly situated because of intentional or purposeful discrimination, and that Plaintiff failed to identify any such similarly situated individuals. The Court reserved

decision on the motion. (See Dkt. 203). On March 15, 2024, the jury returned its verdict, finding in Plaintiff’s favor on the Equal Protection claim against Tanea, but otherwise

2 The Court’s determination in this respect was based on what it perceived Plaintiff’s argument to be at the time—i.e., that Plaintiff should have been permitted to be housed in 9-block but to travel to 10-block for work—and therefore the cellblock move sheets showing the movement of inmates among the blocks in prison would have contained relevant information. But at trial, Plaintiff clarified that his claim was not that he should have been permitted to work in 10-block and live in 9-block, but that he should have been permitted to relocate to 10-block for purposes of his programming. Plaintiff maintained that the cellblock move sheets still would have included information relevant to his claim. finding in favor of Defendants. (Dkt. 206). Plaintiff filed a Notice of Appeal on March 25, 2024. (Dkt. 213).3 Tanea filed a motion for judgment as a matter of law on April 11, 2024.4 (Dkt.

215). Plaintiff filed a response to Tanea’s motion on May 20, 2024. (Dkt. 218). DISCUSSION I. Legal Standard Under Rule 50, the Court may grant a motion for judgment as a matter of law in a jury trial if it finds “that a reasonable jury would not have a legally sufficient evidentiary

basis to find for the party” opposing the request. Fed. R. Civ. P. 50(a). The same standard applies when, as here, a party renews its request for judgment as a matter of law after the trial is complete. See Fed. R. Civ. P. 50(b). “In ruling on a motion for judgment as a matter of law, the court may not itself weigh credibility or otherwise consider the weight of the evidence; rather, it must defer to

the credibility assessments that may have been made by the jury and the reasonable factual inferences that may have been drawn by the jury.” Williams v. Cnty. of Westchester, 171 F.3d 98, 101 (2d Cir. 1999); see also Stevens v. Rite Aid Corp., 851 F.3d 224, 228 (2d Cir. 2017) (“Judgment as a matter of law may not properly be granted

3 Although Plaintiff has filed a Notice of Appeal, the Court retains jurisdiction to address Tanea’s timely-filed Rule 50(b) motion. See Iannone v. Frederic R. Harris, Inc., 941 F. Supp. 403, 409 (S.D.N.Y. 1996).

4 Defense counsel stated in his motion papers that he ordered a copy of the trial transcript following the trial and reserved the right to supplement the motion upon receipt of the same. (See Dkt. 215-1 at 1). Defense counsel never supplemented the motion papers with the transcript. under Rule 50 unless the evidence, viewed in the light most favorable to the opposing party, is insufficient to permit a reasonable juror to find in his favor.” (citation and alteration omitted)).

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