Steele v. National Railroad Passenger Corporation

CourtDistrict Court, W.D. Washington
DecidedApril 19, 2022
Docket3:19-cv-05553
StatusUnknown

This text of Steele v. National Railroad Passenger Corporation (Steele v. National Railroad Passenger Corporation) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Steele v. National Railroad Passenger Corporation, (W.D. Wash. 2022).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 KYLIE STEELE, CASE NO. C19-5553 BHS 8 Plaintiff, ORDER ON AMTRAK’S MOTION 9 v. FOR A NEW TRIAL, JUDGMENT AS A MATTER OF LAW, OR 10 NATIONAL RAILROAD PASSENGER REMITTITUR CORPORATION, 11 Defendant. 12

13 THIS MATTER is before the Court on Defendant Amtrak’s Motion for a New 14 Trial, for Judgment as a Matter of Law, or, in the Alternative, Remittitur, Dkt. 99. The 15 motion follows a jury trial and a $6.875 million verdict in Plaintiff Kylie Steele’s favor. 16 Amtrak argues that it is entitled to a new trial under Federal Rule of Civil 17 Procedure 59(a)(1)(A), for several reasons. First, it argues that the Court violated 18 Amtrak’s Seventh Amendment right to a jury trial, or at least abused its discretion, when 19 it ordered that the trial be conducted by ZOOM, over Amtrak’s objection. Dkt. 99 at 20 2–11. Second, it argues that the Court denied Amtrak a fair trial when it required Amtrak 21 to introduce Steele’s medical records individually, through a witness, and declined to 22 1 permit Amtrak to admit all of her records en masse. Id. at 12–17. Third, Amtrak argues 2 that it is entitled to a new trial because the verdict was “clearly against the weight of the 3 evidence.” Id. at 17–19.

4 Amtrak also seeks judgment as a matter of law on Steele’s claim for future 5 economic losses, arguing the verdict is not supported by substantial evidence. Id. at 6 19–24. As an alternative, it seeks a substantial remittitur of the Jury’s $3.7 million future 7 economic damages award. Id. at 24–27. 8 The issues are addressed in turn.

9 A. Amtrak is not entitled to a new trial based on the ZOOM format. 10 Amtrak seeks a new trial based on its claim that the Court abused its discretion in 11 ordering that the trial be held on the ZOOM platform, over Amtrak’s objection. Dkt. 99 at 12 2–6. 13 As an initial matter, Amtrak did not expressly object to the ZOOM format at the

14 September 27, 2021 Pretrial Conference, at which the virtual format was discussed. At 15 the start of that conference, the Court told the parties that the then-scheduled October 12 16 trial date would have to moved, due to the Court’s calendar.1 Dkt. 78 at 3. Amtrak’s 17 attorney informed the Court that there had been a “bad derailment” in Montana, and 18 expressed his concern trying this case in the wake of bad publicity regarding that

20 1 The Court held a ZOOM jury trial in a civil case, Berg v. Bethel School District, No. 18-cv-5345 BHS, from Tuesday, October 5 to the Jury’s Verdict on Wednesday, October 20. It 21 conducted a live jury trial in a criminal case, United States v. Marschall, No. 20-cr-5270 BHS, beginning with jury selection on Monday October 18 (while the Berg virtual jury was 22 deliberating), and concluding with a verdict on Friday, October 22. 1 derailment. See id. at 3–4. He asked if a continuance to December might lead to an 2 in-person trial, and the Court informed him that that was “conceivable,” but that the 3 Court did not have a crystal ball and that Pierce County was having the highest infection

4 rates it had had since the pandemic began. Id. at 4. Steele objected to a longer 5 continuance, and the parties and the Court agreed on a November 16 trial date, likely by 6 ZOOM. Id.; see also Dkt. 53 (“This is likely to be a remote/virtual trial.”). 7 As Amtrak implicitly concedes, the matter is addressed to the Court’s discretion, 8 and the Court can order a trial over ZOOM based on good cause and compelling

9 circumstances. Bao Xuyen Le v. Reverend Dr. Martin Luther King, Jr. Cnty., 524 F. 10 Supp. 3d 1113, 1115–16 (W.D. Wash. 2021) (Federal Rules of Civil Procedure 43(a) and 11 77(b) authorize the Court to “permit testimony in open court by contemporaneous 12 transmission from a different location,” for good cause in compelling circumstances); see 13 also Order for Remote / Virtual Civil Jury Trial, Orn v. City of Tacoma, No. 3:13-cv-

14 05974 MJP (W.D. Wash. Nov. 19, 2020), Dkt. 205 (holding a ZOOM trial over party’s 15 objection). 16 Amtrak argues the Court’s decision to hold the trial over ZOOM was inconsistent 17 with the then-applicable General Order No. 10-21, which, unlike the General Order in 18 effect when Le was decided, permitted live trials: “All civil, criminal, and bankruptcy in-

19 person hearings and trials may proceed as scheduled. The courthouses are open to the 20 public.” Dkt. 99 at 4–5 (citing W.D. Wash. General Order No. 10-21 at 2 (June 30, 21 2021)). But that Order also acknowledged that the pandemic was not over, and that the 22 then-dominant Delta variant had led to an increase in cases and renewed protective 1 measures. It specifically ordered: “Civil bench and jury trials may be conducted remotely 2 over Zoom.gov if good cause is established for such a procedure on a case-by-case basis, 3 at the discretion of individual judges.” General Order No. 10-21 at 3.

4 Amtrak argues that due to vaccinations and falling infection rates, it was an abuse 5 of discretion to require a ZOOM trial, a claim it argues is proven by the Court 6 subsequently reversing its similar Order in Norvell v. BNSF, No. 17-cv-5683 BHS, a case 7 that went to trial two weeks after Steele. In Norvell, the Court ordered a ZOOM trial, over 8 BNSF’s formal objection, on November 9, 2021. See Order, Norvell v. BNSF,

9 No. 17-cv-5683 BHS (W.D. Wash. Nov. 9, 2021), Dkt. 154. Norvell had a trial date of 10 November 30.2 Id. The Court reiterated its decision to try this case over ZOOM on 11 November 10, Dkt. 60, and the ZOOM trial began six days later, on November 16, Dkt. 12 70. 13 On November 19, the Court ordered that Norvell would be tried in person,

14 notwithstanding the Court’s prior Order. See Minute Order, Norvell, No. 17-cv-5683 15 BHS, Dkt. 172. The fact that Norvell was the first in-person civil jury trial this Court has 16 held since the pandemic began is not proof that the Court abused its discretion in not 17 trying this case in person, or in refusing to continue the case again. The purpose of a 18 ZOOM trial is, primarily, to protect jurors summoned to the Court, many against their

19 own wishes. This includes protecting the jury pool from each other in the jury assembly 20 2 Amtrak argues that it sought only a short continuance, which in hindsight would have 21 led to an in-person trial. Dkt. 99 at 5. But the Court did not have a place in its calendar for a short continuance, in part because of the scheduled trial in Norvell—a case that was older than Steele. 22 The Court’s schedule was discussed at the September 27 Pretrial Conference. Dkt. 78. 1 room, particularly when there are multiple trials being held in the Federal Courthouse, 2 requiring large numbers of potential jurors. It also is an effort in uncertain times to 3 protect witnesses, litigants, their attorneys, and the Court staff. This Court prefers live

4 trials, but the Court exercised its discretion to hold a ZOOM trial in the face of the 5 continuing pandemic. Its decision to return to in person trials earlier than it expected (in 6 Norvell) was not the result of any perceived issue in the Steele ZOOM trial. 7 At the time this trial started, the Court decided to be cautious, and to heed the 8 Chief Judge’s request that civil trials continue to be held virtually, even though criminal

9 trials were being held live, and notwithstanding the General Order’s new language. 10 Infection rates were not falling dramatically, and the Delta variant was becoming more 11 prevalent.3 The fact that the Court held one in-person civil jury trial last fall is not 12 evidence Amtrak did not get a fair trial, or that the Court abused its discretion in trying 13 the matter virtually.

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Steele v. National Railroad Passenger Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/steele-v-national-railroad-passenger-corporation-wawd-2022.