Opinion
CIVIL ACTION NO. 3:17-89
06-10-2019
ANGELA HYMAN, Plaintiff, v. BRYAN DEVLIN, Defendant.
MEMORANDUM ORDER
AND NOW, this 10 day of June, 2019, upon consideration of Plaintiff's Motion for Reconsideration of Order Reducing Punitive Damages Award (ECF No. 162), IT IS HEREBY ORDERED that the Motion is DENIED.
I. Background
This civil action arose from a Pennsylvania State Police Trooper's intervention in the civil repossession of an automobile in Nanty Glo, Pennsylvania. (See ECF No. 99.) The case proceeded to a jury trial on January 29, 2019. (See ECF No. 140.) On February 1, 2019, the jury returned a verdict in Plaintiff's favor, awarding her $5,000 in compensatory damages and $500,000 in punitive damages. (ECF No. 143.)
On May 28, 2019, the Court granted Defendant's post-trial motion (ECF No. 148) and reduced the jury's punitive damages award to $30,000. (ECF No. 161.) The Court found that the jury's punitive-damages award was unconstitutionally excessive. (Id. at 40-44.) In the instant Motion, Plaintiff requests that the Court reinstate the jury's $500,000 punitive-damages award.
II. Standard of Review
Under Rule 59(e) of the Federal Rules of Civil Procedure, a party may file a motion to alter or amend a judgment no later than 28 days after the entry of the judgment. FED. R. CIV. P. 59(e).
"A motion for reconsideration is a limited vehicle used 'to correct manifest errors of law or fact or to present newly discovered evidence.'" Jackson v. City of Phila., 535 F. App'x 64, 69 (3d Cir. 2013) (quoting Max's Seafood Café ex rel. Lou-Ann, Inc. v. Quinteros, 176 F.3d 669, 677 (3d Cir. 1999)). "Accordingly, a judgment may be altered or amended if the party seeking reconsideration shows at least one of the following grounds: (1) an intervening change in the controlling law; (2) the availability of new evidence that was not available when the court granted the motion for summary judgment; or (3) the need to correct a clear error of law or fact or to prevent manifest injustice." U.S. ex rel. Schumann v. Astrazeneca Pharm. L.P., 769 F.3d 837, 848-49 (3d Cir. 2014) (quoting Max's Seafood Café, 176 F.3d at 677) (internal quotation marks omitted).
"Motions for reconsideration are not designed to provide litigants with a 'second bite at the apple.'" Cole's Wexford Hotel, Inc. v. UPMC & Highmark Inc., No. CV 10-1609, 2017 WL 432947, at *2 (W.D. Pa. Feb. 1, 2017) (quoting Bhatnagar v. Surrendra Overseas Ltd., 52 F.3d 1220, 1231 (3d Cir. 1995)). "A motion for reconsideration is not to be used to relitigate, or 'rehash,' issues the court already decided, or to ask a district court to rethink a decision it, rightly or wrongly, already made." Cole's Wexford Hotel, 2017 WL 432947, at *2 (citing Williams v. City of Pittsburgh, 32 F. Supp. 2d 236, 238 (W.D. Pa. 1998)). "By reason of the interest in finality, at least at the district court level, motions for reconsideration should be sparingly granted." Cole's Wexford Hotel, 2017 WL 432947, at *1.
III. Discussion
In her Motion for Reconsideration, Plaintiff argues that the Court must reinstate the jury's punitive-damages award because the Court relied on an improper ratio of punitive damages to compensatory damages. (ECF No. 162 at 1-2.) The Court acknowledges that it improperly stated that the ratio in this case was 500:1, when the ratio was actually 100:1. (See ECF No. 161 at 43.) However, this was a typographical error. The Court was obviously aware of the jury's verdict and that the ratio of punitive damages to compensatory damages was 100:1 in this case. The Court reiterates its finding that the jury did not have a basis to award $5,000 in compensatory damages and $500,000 in punitive damages. On its face, the jury's punitive-damages award violated the Due Process Clause because it was arbitrary and excessive. Therefore, the Court will not reinstate the jury's punitive-damages award.
Moreover, Trooper Devlin's conduct was not reprehensible enough to justify a 100:1 ratio of punitive damages. Plaintiff argues that the jury's punitive-damages award comports with due process because Trooper Devlin's conduct was particularly reprehensible. (ECF No. 162 at 2-3.) Plaintiff claims that, in reducing the punitive-damages award, the Court overlooked the potential harm that could have resulted from Trooper Devlin's conduct and his misrepresentations after the repossession. (Id.) However, in reducing the punitive-damages award, the Court acknowledged that Devlin's conduct could have resulted in physical harm. (ECF No. 161 at 40-41.) The Court stands by its conclusion that the potential physical harm in this case does not justify more than $30,000 in punitive damages. Further, Devlin's alleged misrepresentations after the repossession do not alter the Court's analysis.
Therefore, the Court affirms that Plaintiff is entitled to $30,000 in punitive damages.
IV. Conclusion
AND NOW, this 10 day of June, 2019, for the reasons stated in this Memorandum Order, IT IS HEREBY ORDERED that Plaintiff's Motion for Reconsideration of Order Reducing Punitive Damages Award (ECF No. 162) is DENIED.
BY THE COURT:
/s/ _________
KIM R. GIBSON
UNITED STATES DISTRICT JUDGE