Standberry v. Ramsey County

Background

This case arises from the death of Nekeya Tamara Moody following a medical call involving the Ramsey County Sheriff's Office in February 2020. Plaintiff Myia Angela Standberry, as trustee for Moody's next of kin, filed suit in January 2023 against Ramsey County and two sheriff's deputies, Steven Eddicus and Joe Stradinger, in their individual and official capacities.

In June 2025, the court granted defendants' motion to exclude the expert testimony of Dr. Ronald K. Wright and granted in part and denied in part defendants' motion for summary judgment, leaving three counts for trial. A jury trial was held April 13–15, 2026, and the jury returned verdicts for all defendants on April 15, 2026. Standberry then moved for a new trial under Federal Rule of Civil Procedure 59(a)(1)(A).

Legal Standard

Under Rule 59(a)(1)(A), a court may grant a new trial after a jury verdict "for any reason for which a new trial has heretofore been granted in an action at law in federal court." The Eighth Circuit has held that a new trial is appropriate when the original trial "resulted in a miscarriage of justice" due to a verdict against the weight of the evidence, an excessive damages award, or legal errors at trial. A court may not grant a new trial merely because it would have decided differently than the jury. Evidentiary errors warrant a new trial only when they affected a party's substantial rights. District courts have broad discretion in ruling on new trial motions.

Issue I: Weight of the Evidence

Standberry argued that the jury's finding that Moody did not suffer from a serious medical need on February 6, 2020 was against the great weight of the evidence. She pointed to evidence that Moody lost consciousness while being restrained by the deputies, that the deputies were uncertain about her condition, and that paramedics later found Moody experiencing breathing issues and cardiac arrest.

Defendants countered that evidence showed Moody had a pulse and was breathing on her own after losing consciousness and until paramedics took over. A paramedic testified that upon arrival she observed Moody's chest rising and falling.

The court found the jury's verdict did not go against the great weight of the evidence. Although the court acknowledged it might have found differently, it determined the verdict did not result in a miscarriage of justice given the defendants' evidence of Moody's breathing and pulse while awaiting paramedics. The motion was denied on this argument.

Issue II: Exclusion of Evidence — Four Challenged Rulings

A. Exclusion of Dr. Wright's Expert Testimony

Standberry referenced the pretrial exclusion of Dr. Ronald K. Wright's expert testimony. The court noted that a motion for a new trial is not the appropriate vehicle to challenge a pretrial summary judgment ruling (a motion to reconsider under Local Rule 7.1(j) would be, though Standberry did not obtain prior court permission or show compelling circumstances). On the merits, the court reaffirmed that Dr. Wright's one-page report failed to comply with Federal Rule of Evidence 702 and Federal Rule of Civil Procedure 26(a) because it did not contain information about his methodology or its reliability. The court found no legal error.

B. Exclusion of Other Expert Testimony on Asphyxiation

A pretrial ruling on a motion in limine (a pretrial request to exclude evidence) barred Standberry from presenting other expert testimony about asphyxiation. The court noted its ruling was expressly limited to expert opinions and did not prevent Standberry from asking fact-based questions about Moody's death. The exclusion was grounded in Rule 26(a)'s expert disclosure requirements because Standberry had not notified defendants of any other expert opinion on asphyxiation during discovery. The court found no legal error.

C. Exclusion of a Medical Article Under the Learned Treatise Hearsay Exception

Standberry sought to read portions of an article about prone restraint cardiac arrest into evidence as a "learned treatise" under Federal Rule of Evidence 803(18). That exception permits statements from a learned treatise to be read into evidence if (A) the statement is called to the attention of an expert on cross-examination or relied on by an expert on direct examination, and (B) the publication is established as a reliable authority by the expert's admission or testimony, by another expert's testimony, or by judicial notice.

Standberry introduced the article while cross-examining Dr. Butch Huston, the medical examiner. Dr. Huston stated he was familiar with the article's author, theory, and journal but would not call the article or the journal reliable. Based on Dr. Huston's reluctance, the court declined to take judicial notice of the article's reliability and found Standberry had not established it as a reliable authority. The court found no legal error and reaffirmed its decision not to take judicial notice.

D. Defense Counsel's Comment on Plaintiff's Failure to Call a Medical Expert

Standberry challenged the court's decision to allow defense counsel to comment to the jury on her failure to call a medical expert. Under Eighth Circuit precedent, statements in closing argument constitute reversible error only if they are "plainly unwarranted and clearly injurious." Courts have found no error when counsel points out the absence of expert testimony on issues of central importance to the case.

Because Moody's cause of death was of central importance on all three remaining counts, the court found defense counsel's comments regarding the absence of a medical expert were relevant and not plainly unwarranted or clearly injurious. The court found no legal error.

Disposition

The court denied Standberry's motion for a new trial in its entirety, finding neither that the verdict went against the great weight of the evidence nor that any legal error occurred at trial.