Pierce v. East Bay Municipal Utility District

Background

After a jury trial, defendants moved for judgment as a matter of law, a new trial, or remittitur. Judgment as a matter of law is a request to set aside a verdict because the evidence was legally insufficient. A new trial asks the court to hold another trial. Remittitur asks the court to reduce a damages award.

Retaliation claims

The court denied defendants’ renewed motion for judgment as a matter of law on plaintiffs’ retaliation-based claims. It held that a reasonable jury had a legally sufficient evidentiary basis to find for plaintiffs on those claims.

The court also denied defendants’ motion for a new trial. It found that the jury’s retaliation verdicts were not contrary to the clear weight of the evidence, did not involve a miscarriage of justice, and were not based on excessive damages. Although the damages awards were substantial, the court found that they were rooted in the evidence presented at trial and were not grossly excessive.

Bland’s race-discrimination claims

The court denied without prejudice defendants’ renewed motion for judgment as a matter of law on plaintiff Bland’s race-discrimination claims. The jury had deadlocked on those claims, and Bland agreed not to retry them unless the jury’s verdict in her favor was vacated on appeal. The court therefore did not address the merits of those claims at that time. It allowed defendants to renew their motion if an appellate court later vacates the verdict in Bland’s favor.

Disposition

The court denied defendants’ renewed motion for judgment as a matter of law on the retaliation claims, denied defendants’ motion for a new trial, and denied without prejudice defendants’ renewed motion for judgment as a matter of law on Bland’s race-discrimination claims. The court determined that a hearing on the motions was unnecessary.