Adamson v. City of San Francisco et al

Filing 181

ORDER Denying O'Brien's Rule 50(a) Motion. Signed by Judge Donna M. Ryu on 12/7/2015. (dmrlc3, COURT STAFF) (Filed on 12/7/2015)

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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LORENZO ADAMSON,

Case No. 13-cv-05233-DMR

Plaintiff,
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v.
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United States District Court
Northern District of California

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CHRISTOPHER O’BRIEN; DANIEL
DUDLEY; and BRIAN STANSBURY,

ORDER ON RULE 50(A) MOTION RE
DEFENDANT O’BRIEN

Defendants.

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Plaintiff brought claims for excessive force and punitive damages against each of the three

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Defendants. The court presided over a jury trial in this matter. On November 17, 2015, before the

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case was submitted to the jury, Defendants made an oral motion for judgment as a matter of law

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pursuant to Federal Rule of Civil Procedure 50(a). The court took the matter under submission

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pending the jury’s verdict. On November 19, 2015, the jury returned a verdict in favor of

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Defendants Dudley and Stansbury, but did not reach a unanimous verdict with respect to

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Defendant O’Brien. The court now denies O’Brien’s Rule 50(a) motion.

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Rule 50(a) authorizes the court to enter judgment as a matter of law if the party has been

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fully heard on the issue during a jury trial, and the court finds that a reasonable jury would not

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have a legally sufficient evidentiary basis to find for that party on that issue. Fed. R. Civ. Proc.

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50(a). “When deciding whether to grant a Rule 50(a) motion, ‘[t]he court must draw all

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reasonable inferences in favor of the nonmoving party, and it may not make credibility

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determinations or weigh the evidence.’” Velazquez v. City of Long Beach, 793 F.3d 1010, 1018

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(9th Cir. 2015)(quoting Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150 (2000)).

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The court applies the same standard when ruling on a Rule 50(a) motion as it would on a motion

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for summary judgment pursuant to Rule 56. See Reeves, 530 US at 150. Judgment as a matter of

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law is proper if the evidence, construed in the light most favorable to the nonmoving party, allows

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only one reasonable conclusion. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250-251 (1986).

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Much of this case turned on the credibility of the parties. As to Adamson’s claims against

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O’Brien, the jury heard conflicting evidence about O’Brien’s interactions with Adamson during

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the traffic stop, the removal of Adamson from the car, O’Brien’s order that Adamson sit on the

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curb, and O’Brien’s initial and subsequent applications of force. A reasonable juror crediting

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Adamson’s testimony could conclude that any use of force was unreasonable, because the incident

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involved a traffic stop for a minor infraction, Adamson fully complied with instructions or

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explained why he could not do so, and clearly identified himself as a police officer who was
lawfully carrying a firearm. On the same evidentiary record, a reasonable juror could conclude

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United States District Court
Northern District of California

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that O’Brien acted with malice, oppression or in reckless disregard of Adamson’s rights. In sum,

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O’Brien’s Rule 50(a) motion is denied because the jury had a legally sufficient evidentiary basis to

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support a verdict against O’Brien on both claims.

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IT IS SO ORDERED.
Dated: December 7, 2015
______________________________________
Donna M. Ryu
United States Magistrate Judge

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