HYMAN v. CAPITAL ONE AUTO FINANCE et al

Filing 163

MEMORANDUM ORDER denying 162 Motion for Reconsideration of Order Reducing Punitive Damages Award, and as more fully stated in said Memorandum Order. Signed by Judge Kim R. Gibson on 6/10/2019. (dlg)

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF PENNSYLVANIA
ANGELA HYMAN,

)

CIVIL ACTION NO. 3:17-89

)

Plaintiff,

)

JUDGE KIM R. GIBSON

)

v.

)
)

BRYAN DEVLIN,

)
)

Defendant.

)

MEMORANDUM ORDER
AND NOW, this

Io-f~ay 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 Clo, 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
thatthe 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 punitivedamages 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 (i Phila., 535 F. App'x
64, 69 (3d Cir. 2013) (quoting Max's Seafood Cafe 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 follmving 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

Plzarm. L.P., 769 F.3d 837, 848-49 (3d Cir. 2014) (quoting Max's Seafood Cafe, 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. Surrendm 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

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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

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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

Memorandum

Order,

IT

IO
IS

-th

day of June, 2019, for the reasons stated in this

HEREBY

ORDERED

that Plaintiff's

Motion for

Reconsideration of Order Reducing Punitive Damages Award (ECF No. 162) is DENIED.

BY THE COURT:

KIM R. GIBSON
UNITED STATES DISTRICT JUDGE

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