Edmond Ovasapyan v. City of Glendale

MEMORANDUM

A jury found that two Glendale, California, police officers, Detective Arthur Frank and Lieutenant Ian Grimes (the “Officers”), unlawfully arrested and caused the malicious prosecution of Edmond Ovasapyan. The district court denied the Officers’ motion for judgment as a matter of law, finding that sufficient evidence supported the jury’s verdict. The district court also denied the Officers qualified immunity on both claims, ruling that a reasonable officer would know that the conduct in which they engaged was unlawful. During the punitive damages phase of the trial, the district court quashed subpoenas issued to members of the Glendale City Council. The subpoenas were presumably issued for the purposes of eliciting testimony regarding potential indemnification of the Officers by the City of Glendale. The Officers appeal the district court’s denial of their motion for judgment as a matter of law, and Mr. Ovasapyan appeals the district court’s quashal of the subpoenas. We affirm.

A. The District Court Properly Denied the Officers’ Motion for Judgment as a Matter of Law

Denial of a renewed motion for judgment as a matter of law is reviewed de novo. Gilbrook v. City of…