Maryland Appeals Court Reduces Damages Award
October 15, 2014 By Gerald W. Ueckermann, Jr.
On October 6, 2014, the Maryland Court of Special Appeals decided Francis v. Johnson, which involved a lawsuit brought by a teenager against three Baltimore City police officers. In the case, plaintiff Johnson alleged that after a verbal exchange with the police officers, he was ordered into a police van where he was hit with a baton, choked, and his cell phone was broken in half. He was then driven by the police officers from Baltimore to Ellicott City where they took his socks and shoes, pushed him out of the van, and then drove off.
Johnson filed a lawsuit against the police officers seeking compensatory and punitive damages for violations of his constitutional rights and damages for the common law torts of false imprisonment, battery and assault. At trial, he did not present any evidence of physical injuries or the need for medical or psychological treatment as a result of the incident. A jury subsequently awarded him a total of $465,000 in compensatory damages and $35,000 in punitive damages. In doing so, it awarded him substantial sums for both the constitutional claims and the common law tort claims.
The trial court subsequently reduced the total compensatory damage award from $465,000 to $300,000. The court found that $300,000 was the highest amount of compensatory damages that a reasonable jury could award. The officers felt the reduction should have been greater and appealed.
Although the officers asserted a number of reasons why the award should be reduced, the Court of Special Appeals agreed with only one of those arguments. It found that the constitutional claims and the common law torts were based on the same facts, and that the plaintiff could not recover twice for the same wrong. Therefore, the court held that the plaintiff was not able to recover on his constitutional claims because they were duplicative of the common law claims. The appellate court reduced the awards against the officers by $200,000, which represented the damages for the constitutional claims.
Francis v. Johnson establishes that in cases involving false arrests, jury awards can be reduced if they include duplicative damages. At the same time, however, it demonstrates that appeals courts will allow large awards of non-economic damages to stand even for incidents of relatively short duration that do not result in serious psychological or physical injuries.
The attorneys at DeCaro Doran can assist you in navigating through the confusing issues regarding duplicative claims and damages. Feel free to give us a call on questions you might have on this or any other legal issues you may be facing.