Proper Standard For Granting New Trial Is "Against The Manifest Weight Of The Evidence"
MEJIA v. COOK COUNTY (April 22, 2011)
Michael Mejia was an inmate at the Cook County Jail on October 9, 2005. There was an incident that day and Mejia suffered contusions, lacerations, and bruises. There are significant factual disputes about the incident and the cause of his injuries. Mejia brought suit pursuant to § 1983 against the County and a number of jail employees, alleging excessive force in violation of the Constitution. The case proceeded to trial, where a jury found for the defendants. Judge Lefkow (N.D. Ill.) denied Mejia's motion for a new trial. She concluded that the weight of the evidence supported Mejia but that she could not grant the motion unless a reasonable person could not believe the testimony "because it contradicts indisputable physical facts or laws." Mejia appeals.
In their opinion, Judges Kanne, Wood, and Sykes vacated and remanded. The question presented to the Court was whether the district court applied the proper standard in its ruling on the motion for a new trial. A district court has the power to grant a new trial and should do so when the jury's verdict is against the manifest weight of the evidence. That is not the standard the district court used. Instead, it used the "indisputable facts” standard. But that standard is only used when the district court, in assessing the weight of the evidence, wants to take a piece of evidence out of consideration entirely. The Court noted that applying the "indisputable facts" standard to the weighing process generally would inappropriately raise the bar for a motion for new trial. Having concluded that the district court applied the long standard, the Court considered the County's argument that a remand would be futile because granting the motion would be an abuse of discretion and Mejia's argument that remand would be futile because the district court already decided that the verdict was against the manifest weight of the evidence. The Court rejected both extremes. With respect to the County's argument, the Court declined to express an opinion on the correct outcome once the proper standard is applied. With respect to Mejia's argument, the Court noted that the district court concluded only that the evidence tended to favor Mejia, not that the verdict was against the manifest weight of the evidence.
Michael Rigney practices in the law offices of GVC Ltd. in Chicago. In this blog, he reports on select