Sykes v. Anderson, 08-2088 - U.S. Sixth Circuit
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Sykes v. Anderson, 08-2088

Civil rights action against police officers and a city

Sykes v. Anderson, 08-2088, concerned a challenge to a jury verdict in favor of the plaintiffs on their claims against two police officers and award of over $2.5 million in compensatory and punitive damages, in plaintiffs' 42 U.S.C. section 1983 actions against several police officers, asserting claims of false imprisonment, malicious prosecution, and denial of due process, and against the City of Detroit claiming that the city failed to respond to citizen complaints and that it failed to train and supervise its employees, following their overturned convictions for state crimes of "Larceny by Conversion" and "False Report of a Felony."

In affirming in part, the court held that defendants' qualified immunity claim is waived as their failure to make a pre-verdict motion for judgment as a matter of law under Rule 50(a) on the grounds of qualified immunity precluded them from making a post-verdict motion under Rule 50(b) on that ground.  The court also affirmed the district court's judgment as to plaintiffs' claim of false arrest, because probable cause was lacking at the time the officer submitted a warrant application.  Further, judgment against the defendants as to the plaintiffs' claims for malicious prosecution is affirmed as the record contains ample evidence that the officer influenced or participated in the ultimate decision to prosecute plaintiffs by way of his knowing misstatements to the prosecutor.  Lastly, the court affirmed the judgment against the defendants as to the plaintiffs' due-process claims, and held that the district court did not abuse its discretion in denying defendants' motion for a new trial.  However, because the district court failed to articulate a basis for its denial of the defendants' motion for remittitur, the matter is remanded for the sole purpose of having the district court explain its reasons for denying remittitur.

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