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Sixth Circuit Upholds $2.5 Million Jury Award for Wrongly Convicted Women
By Matt Clarke
On April 12,2011, the Sixth Circuit Court of Appeals issued an opinion upholding the $2.5 million jury award and $250-per-hour attorney-fees award to two women who were wrongly convicted of felonies.
Kimberly Sykes and Tevya Grace Urquhart were wrongly convicted of larceny by conversion and false report of a felony. The Michigan Court of Appeals eventually overturned their convictions. They then filed a civil rights suit in federal district court pursuant to 42 U.S.C.§ 1983 for denial of due process with pendent state law claims for false imprisonment and malicious prosecution. A jury found police sergeants Derrick Anderson and Carol Nichols liable and awarded plaintiffs over $2.5 million in compensatory and punitive damages. Defendants appealed.
The Sixth Circuit affirmed the finding of liability and remanded the case to the district court to “articulate, in the first instance, an explanation for its denial of the Defendants’ motion for remittitur.”
The district court explained that the compensatory damages were within reach of the plaintiffs’ lost earnings from the time of the criminal trial until their retirement at age 65 with noneconomic damages (primarily psychological damage from the trial and imprisonment) making up the remainder of the compensatory damages award. The “district court also found that the four-to-one ratio of compensatory-to-punitive damages was not ‘excessive in light of the direct link between Defendants’ actions and Plaintiffs’ false arrests, convictions, and incarceration.’”
The court of appeals accepted the district court’s explanations and found no abuse of discretion in the denial of remittitur, noting that defendants had already waived any argument that their actions were not reprehensible enough to support a punitive-damages award. The court of appeals affirmed the damages award. It also addressed the defendants’ attempt to reduce the attorney fees, holding that the $250-per-hour award was reasonable as was the number of hours calculated. It also denied plaintiffs’ cross-appeal seeking to increase the attorney fees award. See: Sykes v. Anderson, 625 F.3d 296 (6th Cir., 2010).
On April 12,2011, the Sixth Circuit Court of Appeals issued an opinion upholding the $2.5 million jury award and $250-per-hour attorney-fees award to two women who were wrongly convicted of felonies.
Kimberly Sykes and Tevya Grace Urquhart were wrongly convicted of larceny by conversion and false report of a felony. The Michigan Court of Appeals eventually overturned their convictions. They then filed a civil rights suit in federal district court pursuant to 42 U.S.C.§ 1983 for denial of due process with pendent state law claims for false imprisonment and malicious prosecution. A jury found police sergeants Derrick Anderson and Carol Nichols liable and awarded plaintiffs over $2.5 million in compensatory and punitive damages. Defendants appealed.
The Sixth Circuit affirmed the finding of liability and remanded the case to the district court to “articulate, in the first instance, an explanation for its denial of the Defendants’ motion for remittitur.”
The district court explained that the compensatory damages were within reach of the plaintiffs’ lost earnings from the time of the criminal trial until their retirement at age 65 with noneconomic damages (primarily psychological damage from the trial and imprisonment) making up the remainder of the compensatory damages award. The “district court also found that the four-to-one ratio of compensatory-to-punitive damages was not ‘excessive in light of the direct link between Defendants’ actions and Plaintiffs’ false arrests, convictions, and incarceration.’”
The court of appeals accepted the district court’s explanations and found no abuse of discretion in the denial of remittitur, noting that defendants had already waived any argument that their actions were not reprehensible enough to support a punitive-damages award. The court of appeals affirmed the damages award. It also addressed the defendants’ attempt to reduce the attorney fees, holding that the $250-per-hour award was reasonable as was the number of hours calculated. It also denied plaintiffs’ cross-appeal seeking to increase the attorney fees award. See: Sykes v. Anderson, 625 F.3d 296 (6th Cir., 2010).
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Related legal case
Sykes v. Anderson
| Year | 2010 |
|---|---|
| Cite | 625 F.3d 296 (6th Cir., 2010) |
| Level | Court of Appeals |
| Damages | 2,583,000.00 |
| Injunction Status | N/A |