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Campbell v. District of Columbia

United States District Court, District of Columbia

May 25, 2016

JENNIFER B. CAMPBELL, Plaintiff,
v.
DISTRICT OF COLUMBIA, Defendant. Re Document No. 83

          MEMORANDUM OPINION

          RUDOLPH CONTRERAS United States District Judge

         Denying Defendant’s Motion for Judgment as a Matter of Law

         I. INTRODUCTION

         After a five-day trial, a jury found that, in the process of terminating Plaintiff Dr. Jennifer Campbell’s employment, Defendant District of Columbia denied her the procedural due process that it owed her under the Fifth Amendment of the Constitution. The Court entered judgment against the District in the amount of $554, 823, which reflected (1) the jury’s award of compensatory damages for Dr. Campbell’s physical pain, emotional distress, humiliation, embarrassment, inconvenience, and medical expenses ($250, 000); and (2) Dr. Campbell’s financial damages in the amount to which the parties stipulated before trial ($304, 823).

         The District now moves to set aside the jury’s verdict, or, alternatively, to reduce the judgment to just $250, 000, the jury’s compensatory damages award. Because the District has shown neither that no reasonable jury could have reached a verdict in Dr. Campbell’s favor, nor that the Court must set aside the parties’ stipulation of financial damages to prevent manifest injustice, the Court will deny the District’s motion.

         II. BACKGROUND

         Dr. Campbell brought suit against her former employer, the District of Columbia, in 2012. See Compl., ECF No. 1. Dr. Campbell alleged that the District acted unlawfully when, amidst allegations that Dr. Campbell had steered contracts, and in the wake of media articles publicizing those allegations, the District terminated her employment as Chief Operating Officer of the District’s Department of Health Care Finance. See Id. ¶¶ 6-99.

         After the Court resolved the District’s dispositive motions, the parties prepared for trial on Dr. Campbell’s constitutional claims brought under 42 U.S.C. § 1983 and on her claims under the District of Columbia’s Whistleblower Protection Act (WPA), D.C. Code §§ 1-615.51 to -615.59. See Joint Pretrial Statement 1, ¶ II, ECF No. 41 (stating Dr. Campbell’s claims for trial). Before trial, the parties stipulated that “[t]he amount of [Dr. Campbell’s] lost wages relating to her claims is $304, 823.” Id. at 2, ¶ III.2. In light of that stipulation, Dr. Campbell agreed not to call expert witnesses to testify at trial about her damages. Nov. 30, 2015 Order 2, ¶ I.4, ECF No. 48.

         The parties tried Dr. Campbell’s case before a jury for five days in December 2015. After Dr. Campbell presented her case-in-chief, the Court granted the District’s motion for judgment as a matter of law on Dr. Campbell’s WPA claim. See Dec. 9, 2015 Trial Tr. 9:18-11:21, ECF No. 81. But Dr. Campbell’s constitutional claims were submitted to the jury for consideration, and the jury found for Dr. Campbell on one of those claims. See Verdict Form 2, ECF No. 65. The jury found that, by terminating Dr. Campbell’s employment without due process and in a manner that “left a stigma on her by having the broad effect of largely precluding her from pursuing her chosen career, ” the District denied Dr. Campbell procedural due process and deprived her of her constitutionally protected right to pursue her chosen field of employment. See id.; see also Jury Instructions 28-38, ECF No. 66. The jury awarded Dr. Campbell $250, 000 in compensatory damages for her physical pain, emotional distress, humiliation, embarrassment, inconvenience, and medical expenses. See Verdict Form 3; see also Jury Instructions 39-40 (instructing the jury to award monetary damages for physical pain, emotional distress, humiliation, embarrassment, inconvenience, and medical expenses, but not for lost wages or other benefits).

         The Court entered judgment against the District in the amount of $554, 823. See Final J., ECF No. 75. The final judgment reflected (1) the jury’s compensatory damages award ($250, 000) and (2) Dr. Campbell’s financial damages in the amount to which the parties stipulated before trial ($304, 823). See Campbell v. District of Columbia, No. 12-1769, 2016 WL 247560, at *2 (D.D.C. Jan. 20, 2016) (explaining the components of Dr. Campbell’s damages award).

         The District now argues, as it did at trial, that “no reasonable juror could find that [Dr. Campbell] could have suffered the broad stigma necessary to sustain” the constitutional claim on which she received a favorable jury verdict. Def.’s Mot. J. Matter of Law 1, ECF No. 83 [hereinafter Def.’s Mot]; see Dec. 10, 2015 Trial Tr. 137:8-139:19, ECF No. 82 (making the argument at trial). Moving under Federal Rule of Civil Procedure 50, the District asks the Court to set aside the jury’s verdict and enter judgment as a matter of law in favor of the District. See Def.’s Mot. 1.

         The District also asserts that Dr. Campbell should not receive a financial damages award of $304, 823. See Mem. P. & A. Supp. Def.’s Mot. J. Matter of Law 8-9, ECF No. 83-1 [hereinafter Def.’s Mem.]. In support, the District (1) notes that the parties stipulated to Dr. Campbell’s lost wages when her WPA claim was still part of the case, (2) asserts that Dr. Campbell did not present evidence at trial showing that “her lost wages were a result of the lack of due process in connection with her termination, ” and (3) argues that any additional remedy for Dr. Campbell’s procedural due process claim should be a “name clearing hearing.” See Id. The District contends that, if the Court refuses to set aside the jury’s verdict, the Court should “reduce the judgment to the $250, 000 awarded by the jury.” See Id. at 9.

         The Court addresses both of the District’s requests in turn.

         III. REQUEST TO SET ASIDE THE JURY VERDICT

         A. Legal Standard

         Federal Rule of Civil Procedure 50(a) allows a party in a jury trial to make a motion for judgment as a matter of law after “a party has been fully heard on an issue” and “before the case is submitted to the jury.” Fed.R.Civ.P. 50(a). If the Court finds that “a reasonable jury would not have a legally sufficient evidentiary basis” to find for the nonmoving party on that issue, then the Court may grant the motion for judgment as a matter of law on any “claim or defense that, under the controlling law, can be maintained or defeated only with a favorable finding on that issue.” Id. If the Court does not grant the motion, however, ...


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