Nathson Fields v. City of Chicago
981 F.3d 534 · Court of Appeals for the Seventh Circuit · 2020
Facts
Nathson Fields was convicted of the 1984 murders of Talman Hickman and Jerome Smith, and his conviction and death sentence were affirmed in 1990. In 1998, his convictions were overturned due to evidence that his co-defendant's attorney bribed the trial judge, undermining confidence in the outcome. Fields was acquitted in a retrial in 2009. He then filed a civil suit alleging Chicago Police Detectives David O’Callaghan and Joseph Murphy violated his constitutional rights by fabricating evidence, engaging in suggestive identification procedures, and withholding exculpatory evidence. Fields also alleged the City of Chicago had a policy of withholding "street" files containing exculpatory evidence.
Procedural history
Nathson Fields filed a § 1983 and state law lawsuit in 2010 against the City of Chicago and individual defendants. The case proceeded to trial in March 2014, but a mistrial was declared after seven days. A second trial commenced in April 2014, where the jury found for Fields against O’Callaghan, awarding $80,000. The district court granted Fields’s motion for a new trial on other claims and damages, and O'Callaghan's motion for a new trial on liability. After a third month-long trial, the jury found for Fields against O’Callaghan, Murphy, and the City, awarding $22 million in compensatory damages and punitive damages, which the defendants then appealed to the Seventh Circuit.
Issue
The individual defendants challenged the district court's evidentiary decisions in the third trial. The City of Chicago challenged the district court's decisions to grant a new trial following the first trial and the denial of its motion for judgment as a matter of law regarding Monell liability after the second trial. The core legal question was whether the district court abused its discretion in its evidentiary rulings and in granting new trials, and whether there was sufficient evidence for Monell liability.
Holding
The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. It found no abuse of discretion in the district court's evidentiary rulings or in its grants of new trials under Rule 60(b)(2) and Rule 59(e). The court also found a legally sufficient evidentiary basis for the jury's finding of Monell liability against the City.
Rule
A trial court's evidentiary decisions are reviewed for abuse of discretion, requiring a substantial and injurious effect for a new trial. Hearsay is inadmissible unless an exception applies, and witness testimony requires personal knowledge. Evidence may be excluded if its probative value is outweighed by prejudice (Rule 403), but "other act" evidence can show intent (Rule 404(b)). New trials can be granted for newly discovered, material, non-impeaching evidence (Rule 60(b)(2)), or for clear and convincing evidence of fraud or misconduct preventing a fair case presentation (Rule 60(b)(3)). A new trial may also be granted if a discovery ruling denied a fair trial (Rule 59(e)). Monell liability requires an unconstitutional act caused by official policy, widespread custom, or deliberate indifference to known risks of constitutional violations.
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