Handy Jones v. City of St. Paul, Minnesota

Background

A jury found on August 2, 2023, that St. Paul police officer Nathaniel Younce used excessive force against Cordale Quinn Handy, causing his wrongful death. The jury found Officer Mikko Norman not liable. It found the City of St. Paul vicariously liable for Younce’s actions as the City’s employee.

The jury awarded Kim Diane Handy Jones, acting as trustee for Handy’s estate, $10 million in compensatory damages and $1.5 million in punitive damages. The City and Younce moved for remittitur, a new trial, or an amended judgment, and asked the court to stay enforcement of the judgment while any appeal was pending.

Remittitur

Remittitur is a court-ordered reduction of a jury’s damages award, usually allowing the plaintiff to accept the reduced amount instead of undergoing a new trial on damages. The court applied Minnesota law, which measures wrongful-death damages by the family’s financial and other legally recognized losses resulting from the death, rather than by the abstract value of a human life. The court stated that damages cannot be based on grief or mental anguish and cannot be speculative.

The court found that the $10 million compensatory award was so excessive that it shocked the court’s conscience, given the limited evidence concerning compensatory damages. The evidence showed that Handy did not financially support his mother or siblings, apart from nonmonetary gifts. There was no evidence about his income, future earning capacity, living expenses, legal support obligations, or the likelihood of paying existing debts. Although Handy worked full time and often worked overtime, the evidence did not establish his income or that he shared it with family members. The evidence also did not provide a monetary value for his skills in drywall work, house painting, or singing. Funeral and burial expenses totaled $15,259.56.

The court found that the strongest evidence concerned the loss of Handy’s future counsel, guidance, aid, advice, comfort, assistance, and protection for his mother and siblings. The evidence showed that he was healthy, had an estimated 41.6 additional years of life expectancy, and was a loving and engaged family member who took special care of his family. Even so, the court concluded that the award was patently excessive, highly speculative, and apparently influenced by grief and mental anguish.

After reviewing similar excessive-force wrongful-death cases, the court determined that $2.5 million was the maximum compensatory amount the jury could reasonably have awarded. The court ordered remittitur to that amount. Jones had to choose whether to accept the reduction from $10 million to $2.5 million. If she accepted it, the court would enter judgment; if she declined, the court would schedule a new trial limited to compensatory damages. The $10 million award remained in place while she made that choice.

Motion for a New Trial or Amended Judgment

The court denied the request for a new trial or amended judgment. It rejected challenges to several evidentiary rulings, including limits on evidence about drugs in Handy’s system and apartment, unresolved criminal charges, a witness’s misdemeanor shoplifting convictions, the officers’ subjective opinions and fears, and expert testimony about the effects of N-Ethylpentylone. The court concluded that the challenged rulings either were not errors or did not prejudice the defendants’ substantial rights.

The court also rejected the challenge to plaintiff’s closing argument. Although the arguments were heated, the court found that plaintiff’s counsel’s statements did not meet the standard requiring a new trial.

The court rejected the argument that the punitive-damages instruction on the state wrongful-death claim was improper because plaintiff had not separately moved to amend the complaint under Minnesota law. The court held that the Federal Rules of Civil Procedure applied after removal to federal court and allowed a party to request punitive damages in the complaint.

Finally, the court rejected the argument that the liability verdict was inconsistent because Younce was found liable while Norman was not. The evidence showed that Younce fired first and Norman fired only afterward. The court concluded that the jury could reasonably find Younce solely responsible and that the verdict was not contradictory.

Stay of Judgment Execution

The court granted the request to stay execution of the judgment pending appeal. Jones did not object to a stay but requested a bond or other security. The court declined to require one because the City had acknowledged that it was ready, willing, and able to pay the judgment if it became final after appeal.

Disposition

The court granted in part and denied in part the defendants’ combined motion. It granted the motion for remittitur, denied the motion for a new trial or to alter or amend the judgment, and granted the motion to stay execution of the judgment pending appeal. It ordered Jones to inform the court by March 1, 2024, whether she would accept the $2.5 million compensatory-damages amount or proceed to a new trial on that issue.